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Cabrillo-Santa Ynez 115 kV Reconductoring Project
Mitigation Monitoring, Compliance, and Reporting Program
Prepared for: California Public Utilities Commission 505 Van Ness Avenue San Francisco, California 94102 Prepared by: RMT Inc. 4 West Fourth Avenue, Suite 303 San Mateo, California 94402
Cabrillo-Santa Ynez 115 kV Reconductoring Project i
June 2010
Table of Contents Chapter 1: Introduction ............................................................................................................................. 1-1
1.1 Authority and Purpose of the Program ................................................................................... 1-1
1.2 Program Adoption Process ........................................................................................................ 1-2
1.3 Project Description ...................................................................................................................... 1-2
1.3.1 Project OVerview ................................................................................................................ 1-2
1.3.2 Construction Components ................................................................................................. 1-3
1.3.3 Project Documents .............................................................................................................. 1-4
1.4 Agency Jurisdiction ..................................................................................................................... 1-5
Chapter 2: Roles and Responsibilities ................................................................................................... 2-1
2.1 Organization Overview .............................................................................................................. 2-1
2.1.1 PG&E Project Construction Manager ............................................................................... 2-1
2.1.2 PG&E Construction Management .................................................................................... 2-1
2.1.3 PG&E Project Environmental Manager ........................................................................... 2-1
2.1.4 CPUC Project Manager ....................................................................................................... 2-3
2.1.5 CPUC Third-Party Monitors .............................................................................................. 2-3
2.1.6 PG&E Environmental Monitors ........................................................................................ 2-3
2.1.7 Construction Personnel ...................................................................................................... 2-3
2.1.8 Mitigation Monitoring Program Contact List ................................................................. 2-4
2.2 Responsibilities ............................................................................................................................ 2-4
2.2.1 Monitoring............................................................................................................................ 2-4
2.2.2 Enforcement ......................................................................................................................... 2-4
2.2.3 Mitigation Compliance ....................................................................................................... 2-5
2.3 Communication ........................................................................................................................... 2-5
2.3.1 Pre-construction Kick-off Meeting .................................................................................... 2-6
2.3.2 Progress Meetings ............................................................................................................... 2-6
2.3.3 Daily Communication ........................................................................................................ 2-6
2.3.4 Communicating Compliance Issues ................................................................................. 2-7
2.3.5 Coordination with Other Agencies ................................................................................... 2-7
2.3.6 Dispute Resolution .............................................................................................................. 2-7
Chapter 3: Environmental Compliance and Field Procedures ........................................................... 3-1
3.1 Mitigation Measures Compliance and Reporting .................................................................. 3-1
TABLE OF CONTENTS
ii Mitigation Monitoring, Compliance, and Reporting Program
3.1.1 Pre-Construction Compliance Verification ...................................................................... 3-1
3.1.2 Notice to Proceed Procedures ............................................................................................ 3-1
3.1.3 Compliance Verification ..................................................................................................... 3-3
3.1.4 Compliance Reporting ........................................................................................................ 3-3
3.1.5 Compliance Levels .............................................................................................................. 3-3
3.2 Project Changes ............................................................................................................................ 3-4
3.2.1 Variance Procedure ............................................................................................................. 3-4
3.2.2 Temporary Extra Work Space Procedures ....................................................................... 3-5
3.3 Records Management.................................................................................................................. 3-6
3.4 Public Access to Records ............................................................................................................ 3-6
Chapter 4: Mitigation Monitoring Program Table ............................................................................... 4-1
4.1 Using the Table ............................................................................................................................ 4-1
4.2 Effectiveness Review ................................................................................................................... 4-1
Appendix A: Project Segment Maps
Appendix B: Project Contact List
Appendix C: Communication Protocol Summary
Appendix D: Variance Request Form
Appendix E: Temporary Extra Work Space Form
Appendix F: Mitigation Monitoring Program Table
LIST OF TABLES
Table 1.3-1: Proposed Construction Schedule ........................................................................................ 1-3
Table 1.4-1: Permits and Approvals Necessary for the Proposed Project ........................................... 1-5
Table 2.2-1: Required On-Site Monitoring ............................................................................................... 2-5
LIST OF FIGURES
Figure 2.1-1: Project Management Organizational Chart ...................................................................... 2-2
Cabrillo-Santa Ynez 115 kV Reconductoring Project 1-1
June 2010
Chapter 1: Introduction
The Final Initial Study/Mitigated Negative Declaration (IS/MND) for the Cabrillo-Santa Ynez 115
kV Reconductoring Project, as adopted by the California Public Utilities Commission (CPUC) on
May 6, 2010, includes procedures for preparing and implementing a Mitigation Monitoring,
Compliance, and Reporting Plan (MMCRP) to ensure compliance with mitigation measures
approved in the Final IS/MND. Chapter 4 of the Final IS/MND provides the recommended
framework for the implementation of the MMCRP by the CEQA Lead Agency, the CPUC, and
describes the roles and responsibilities of government agencies in implementing and enforcing
adopted mitigation measures. This MMCRP includes the information provided in Chapter 4, as
well as specific protocols to be followed prior to and during construction by CPUC third-party
environmental monitors (CPUC EMs) and Pacific Gas & Electric (PG&E) project staff. RMT Inc.
(RMT) will be providing CPUC’s EMs.
The project’s MMCRP includes direct participation and commitment from PG&E and CPUC EMs.
The success of the program depends on the project management staff, monitors, and construction
contractor personnel. The goal of the MMCRP is to provide a clear understanding of the project’s
organization, established lines of communication, and documentation and report compliance
measures with all of the mitigation measures.
The MMCRP was developed to provide guidelines and standardize procedures for environmental
compliance on the project. The procedures have been developed in coordination with PG&E,
CPUC, and RMT to help define the reporting relationships, provide detailed information about the
roles and responsibilities of the project’s environmental compliance team members, define
compliance reporting procedures, and to establish a communication protocol.
1.1 Authority and Purpose of the Program
The California Public Utilities Code, in numerous places, confers authority upon the CPUC to
regulate the terms of service and the safety, practices and equipment of utilities subject to its
jurisdiction. It is the standard practice of the CPUC, pursuant to its statutory responsibility to
protect the environment, to require that mitigation measures stipulated as conditions of approval
are implemented properly, monitored, and reported on. In 1989, this requirement was codified
statewide as Section 21081.6 of the Public Resources Code. Section 21081.6 requires a public agency
to adopt a Mitigation Monitoring, Compliance, and Reporting Program when it approves a project
that is subject to preparation of an IS/MND. CEQA Guidelines Section 15097 was added in 1999 to
further clarify agency requirements for mitigation monitoring or reporting. The CPUC views the
MMCRP as a working guide to facilitate not only the implementation of mitigation measures by
the project proponent, but also the monitoring, compliance, and reporting activities of the CPUC
and any monitors it may designate.
CHAPTER 1: INTRODUCTION
1-2 Mitigation Monitoring, Compliance, and Reporting Program
1.2 Program Adoption Process
The mitigation measures proposed in the Final IS/MND and the framework for this MMCRP, as
described in Chapter 4 of the Final IS/MND, were approved by the CPUC on May 6, 2010, (10-05-
006). A draft version of the MMP was distributed to PG&E, CPUC, and RMT for review and
comment.
1.3 Project Description
1.3.1 PROJECT OVERVIEW The 14.6-mile Cabrillo-Santa Ynez 115 kV power line connects Cabrillo Substation to Santa Ynez
Switching Station, and comprises one segment of an approximately 80-mile 115 kV transmission
loop for the Lompoc-Santa Ynez areas. This loop serves over 71,000 customers in the general area
between Santa Maria, Lompoc, Santa Ynez, and Solvang.
This project would require the following to reduce instances of line failure:
Replacing the existing single-circuit 4/0 AAC with a 715 Multi-Chip Model (MCM), non-
specular AAC on approximately 14.1 miles of an existing 14.6-mile power line
Replacing approximately 125 existing wood poles (currently holding the 4/0 AAC) with
new light-duty steel poles along the power line route
The existing segment of the power line between Cabrillo Substation and Santa Ynez Switching
Station was upgraded from 70 kV to 115 kV with distribution-style dead-end shoes in 1988. The
upgrade cost-effectively provided strength to meet tensioning requirements for this line.
Subsequent investigation has determined this style of distribution design causes excessive bending
of the conductor. The sharp bends, when exposed to the frequent local winds, create cyclic fatigue
in the conductor, and resulting in increased failures.
The coastal climate produces foggy and windy conditions throughout the year, which have
contributed to the accelerated deterioration of the existing conductors and associated hardware,
causing frequent failures. The project would replace aging wood poles with new light-duty steel
poles, and outdated or deteriorated hardware with an upgraded conductor (a heavier 715 MCM
AAC), new insulators, and other required hardware along 14.1 miles of the existing power line.
The remainder of the 80-mile power line extending into Cabrillo Substation does not require
reconductoring because it currently uses the new MCM AAC. Average distances between poles
(i.e., spans) are anticipated to vary between 350 and 780 feet, with a maximum span length
between two poles of less than 1,500 feet.
Conductors and Other Hardware
The existing bare aluminum conductor would be replaced with a new 715 aluminum, non-
specular conductor. Insulators along the entire 14.6-mile line would also be replaced during
construction. The approximate distance from the ground to the lowest conductor would follow
G.O. 95 requirements. All existing communication lines and 12 kV distribution underbuilds that
are collocated with the existing conductor would be moved to the new poles.
CHAPTER 1: INTRODUCTION
Cabrillo-Santa Ynez 115 kV Reconductoring Project 1-3
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Schedule
The project is estimated to begin construction in June 2010 and last approximately 15 months, with
a completion date of August 2011. The Cabrillo-Santa Ynez 115 kV power line would not be
removed from service during the summer because of high seasonal demands. The majority of pole
installation, line reconductoring, and pole removal is expected to be performed throughout the
year with the majority of activities occurring outside the summer months of June, July, and
August. Reconductoring would begin when new poles have been installed along an
approximately 1-mile distance (i.e., approximate length of new conductor reel).The proposed
schedule is presented in Table 1.3-1.
1.3.2 CONSTRUCTION COMPONENTS Components of the proposed project are described in detail below. Segment maps illustrating the
locations of these components are found in Appendix A.
Power Line
The existing line is a 115 kV, single-circuit, 14.6 mile long power line. The proposed
reconductoring on approximately 14.1 miles of this line would not change the line capacity or
length. Other lines, equipment, and utilities, such as communications lines that are collocated on
the existing poles, would be transferred to the new poles.
Poles
The project includes replacing 125 wood poles along the route with new direct-buried, light-duty
steel poles designed to meet General Order 95 (G.O. 95) clearance requirements for the new 715
MCM AAC. Direct-buried poles would not require the installation of foundations. New steel poles
Table 1.3-1: Proposed Construction Schedule
Project Activity Proposed Schedule
Final engineering completed October 2009
Begin acquiring temporary construction easements December 2009
Permit To Construct decision adopted and effective May 6, 2010
Acquire required permits June 2010
ROW and property acquisition Not anticipated; if needed, March 2010
Construction begins: access road re-establishment and pole
installation
June 2010
Pole installation, reconductoring (as pole installation and line
clearances permit), and pole removal
July 2010 through August 2011,
as schedule constraints allow
Project operational August 2011
Cleanup September 2011
CHAPTER 1: INTRODUCTION
1-4 Mitigation Monitoring, Compliance, and Reporting Program
would have a surface treatment designed to mimic the appearance of natural weathering similar to
that of the current wood poles. Steel poles also would provide superior protection from wildfires,
rotting, and woodpecker damage compared to the existing wood poles. The new poles would be
installed consistent with PG&E standard raptor-safe design criteria, which provide 8.5 feet of
clearance between conductors and lower voltage lines located underneath the transmission line
(i.e., underbuild). Triangular raptor perch deterrents would be installed per PG&E guidelines in
areas supporting 12 kV underbuilds. Eight existing wood poles along the route (Poles 1 through 6,
11, and 17) would not be replaced with new steel poles. These poles were recently replaced during
routine or emergency maintenance and are in good condition. Insulator replacement and
reconductoring activities would still be performed in these areas.
The new poles are designed to accommodate sway associated with the new conductor and
suspension-style insulators. The new poles would be buried deeper (11 to 13.5 feet) than existing
poles (7 to 10 feet). Aboveground pole heights would not change significantly, ranging from 49 to
64 feet, except at two locations (i.e., at the SR 246 crossing and in the proximity of a residential
development on the east end of the power line), where poles would be 5 to 12 feet taller than
existing poles to provide adequate ground clearance and reduce electromagnetic fields (EMF) near
residences. Average distances between poles (i.e., spans) are anticipated to vary between 350 and
780 feet, with a maximum span length between two poles of less than 1,500 feet.
Conductors and Other Hardware
The existing bare aluminum conductor (4/0 AAC, seven strand, 0.52 inch in diameter) would be
replaced with a new 715 aluminum, non-specular conductor (715 MCM AAC, 0.97 inch in
diameter).
To optimize the efficiency of operation and maintenance activities, insulators along the entire 14.6-
mile line would also be replaced during construction, creating a consistent age for hardware along
the power line. All existing communication lines and 12 kV distribution underbuilds that are
collocated with the existing conductor would be moved to the new poles.
The approximate distance from the ground to the lowest conductor would follow G.O. 95
requirements:
Thoroughfares traversed by vehicles: 30 feet minimum
Water crossings less than 20 acres: 27 feet minimum
Highway crossings (e.g., SR 246): 30 feet minimum
1.3.3 PROJECT DOCUMENTS
The MMCRP is intended to provide pertinent information necessary to successfully implement the
MMP during construction. The mitigation measures and Applicant Proposed Measures (APM)
listed in Section 4.3 are presented in Chapter 4 of the Final IS/MND. Detailed discussions on the
actions required for each mitigation measure and APM are provided in these sections as well. In
addition to the Final IS/MND, construction activities must be conducted in accordance with the
requirements stipulated in the following documents:
CHAPTER 1: INTRODUCTION
Cabrillo-Santa Ynez 115 kV Reconductoring Project 1-5
June 2010
Stormwater Pollution Prevention Plan (SWPPP), including an Erosion Control and
Sediment Transport Plan (ECSTP)
Worker Environmental Awareness Program (including biological and cultural
resources)
Avian Protection Plan
Hazardous Substance Control and Emergency Response Plan
Fire Prevention and Response Plan
Traffic Management Plan (TMP)
Health and Safety Plan
1.4 Agency Jurisdiction
In addition to the CPUC, several local, state, and federal agencies have jurisdiction over lands that
are crossed by the project route. The CPUC, as the lead agency, is responsible for ensuring that
mitigation measures reviewed and approved by jurisdictional agencies during the Draft IS/MND
process are implemented throughout construction. However, jurisdictional agencies may visit the
project site from time to time and request information regarding the status of a mitigation
measure. In addition, PG&E is required to submit survey results to the US Fish and Wildlife
Service and the California Department of Fish and Game, and consult with these agencies when
project changes affect the condition of their permit. PG&E is responsible for satisfying requests
from jurisdictional agencies, and will notify and copy the CPUC on all correspondences related to
final approvals and permits for the project if the CPUC is not otherwise copied on the
correspondence. Additional information on communication protocols is presented in Section 2.3
below. Table 1.4-1 lists jurisdictional agencies, purpose of consultation, and required permits
associated with the project:
Table 1.4-1: Permits and Approvals Necessary for the Proposed Project
Permit, Approval, or Exemption Purpose Regulating Agency
Federal
Section 7 Consultation: Incidental
Take Permit
Endangered Species Act compliance U.S. Fish and Wildlife Service
Clean Water Act 404 Nationwide
Permit
Discharge of dredged and fill
material into waters of the United
States
U.S. Army Corps of Engineers
State
Consistency Determination Compliance with Section 2080.1 of
the California Endangered Species
Act
California Department of Fish
and Game
CHAPTER 1: INTRODUCTION
1-6 Mitigation Monitoring, Compliance, and Reporting Program
Table 1.4-1 (Continued): Permits and Approvals Necessary for the Proposed Project
Permit, Approval, or Exemption Purpose Regulating Agency
State
Storm Water Pollution
Prevention Plan; enrollment
under General Construction
National Pollution Discharge
Elimination System permit
Road grading and ground
disturbance for pole installation
Central Coast Regional Water
Quality Control Board
Section 401 certification Discharge of dredged and fill
material into waters of the United
States.
Central Coast Regional Water
Quality Control Board
Encroachment Permits For any work to take place within
ROW for US 101, SR 1, and SR 246
California Department of
Transportation
Local
Traffic Control Permit Required for any work within the
ROW for County roadways
Santa Barbara County
Department of Public Works
Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-1
June 2010
Chapter 2: Roles and Responsibilities
This section describes the roles and responsibilities of key project personnel with respect to the
MMCRP. Figure 2.1-1 provides an organizational chart of project members responsible for
implementing the MMCRP and their relationship to other staff working on the project. The
organization chart also establishes preliminary lines of communication between the project team
members.
2.1 Organization Overview
2.1.1 PG&E PROJECT CONSTRUCTION MANAGER
PG&E’s Project Construction Manager (Lee Ellis) provides the overall direction, management,
leadership, and corporate coordination for the construction project. The Project Construction
Manager will be based in PG&E’s San Luis Obispo office, 406 Higuera St., San Luis Obispo for the
duration of construction. The Project Construction Manager’s responsibilities related to the
environmental program include, but are not limited to:
Coordinate between engineering, construction management, and environmental staff;
Provide leadership by integrating environmental responsibilities into all levels of the
project organization;
Ensure compliance with project policies, guidelines, and procedures; and
Communicate project activities, schedules, and public relation issues to the project team.
2.1.2 PG&E CONSTRUCTION MANAGEMENT The Construction Management (TBD) provides support to the Project Construction Manager and
oversees activities of construction staff. The Construction Management will be based out of
PG&E’s Templeton Service Center, 160 Cow Meadow Place, Templeton , but will also typically be
available in the field on a daily basis. Specific responsibilities of the Construction Management
include, but are not limited to:
Ensure compliance with company specifications, permit conditions, construction
contracts, and applicable codes;
Notify Environmental Monitors of project and schedule changes;
Work with Environmental Monitors to evaluate and improve the implementation of the
MMCRP, as construction progresses; and
Regularly facilitate project field meetings.
2.1.3 PG&E PROJECT ENVIRONMENTAL MANAGER PG&E’s Project Environmental Manager (Sam Danner) is responsible for providing the
appropriate level of resources for successful implementation of the MMCRP. The Project
Environmental Manager is responsible for directing development and implementation of
preconstruction environmental planning, permitting and compliance activities, environmental
CHAPTER 2: ROLES AND RESPONSIBILITIES
2-2 Mitigation Monitoring, Compliance, and Reporting Program
CHAPTER 2: ROLES AND RESPONSIBILITIES
Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-3
June 2010
inspection program, and environmental training. The Project Environmental Manager is also
responsible for ensuring compliance with the Section 7 Consultation and 2080.1 Consistency
Determination. The Project Environmental Manager will be based out of PG&E’s San Luis Obispo
Service Center.
2.1.4 CPUC PROJECT MANAGER The CPUC Project Manager will determine the effectiveness of the MMCRP based on the success
criteria included in the mitigation monitoring table. The CPUC will delegate monitoring and
reporting responsibilities to third-party monitors during construction, and will oversee their work
through review of daily and weekly status reports. The CPUC Project Manager will be notified of
noncompliance situations and may suggest measures to help resolve the issue(s). All variance
requests will be submitted to the CPUC Project Manager for review and approval.
2.1.5 CPUC THIRD-PARTY MONITORS
The CPUC will delegate daily monitoring and reporting responsibilities to a third-party
monitoring program. The number of third-party monitors (CPUC EMs) and frequency of site
inspections will depend on the number of concurrent construction activities and their locations.
The CPUC EMs will report directly to the CPUC Monitoring Project Director (CPUC Monitoring
PD) and Project Manager (CPUC Monitoring PM) who will oversee the day-to-day monitoring
activities of the EMs, as well as determine the appropriate level of inspection frequency. The
overall monitoring program will be administered under the direction and oversight of the CPUC
Project Manager. CPUC EMs will be an integral part of the project team, and will stay apprised of
construction activities, schedule changes and construction progress. The CPUC EMs will
document compliance through weekly reports and use of a mitigation measure tracking table.
2.1.6 PG&E ENVIRONMENTAL MONITORS
The PG&E monitoring team will include a Environmental Lead who will coordinate the activities
of the lead, biological, paleontological, cultural, and hazardous materials monitors, as needed, to
comply with each mitigation measure. PG&E Environmental Monitors will work closely with
construction personnel to ensure pre-construction surveys are completed and mitigation measures
are implemented correctly. PG&E Environmental Monitors will also work closely with the CPUC
EMs to determine the effectiveness of mitigation measures, and whether adjustments are needed
to provide adequate protection of sensitive resources.
2.1.7 CONSTRUCTION PERSONNEL The PG&E construction staff and contractor staff have significant responsibilities for compliance
with the environmental requirements of the project. The Construction Manager and contractor(s)
will be responsible for incorporating all project environmental requirements into their day-to-day
construction activities. Key environmental responsibilities for the Construction Manager and
Contractor(s) staff include, but are not limited to:
Verify that all construction workers attend the project’s environmental training program
prior to beginning work on the ROW;
Review and understand the environmental requirements;
Implement environmental protection requirements and conditions during construction;
CHAPTER 2: ROLES AND RESPONSIBILITIES
2-4 Mitigation Monitoring, Compliance, and Reporting Program
Maintain compliance with project requirements; and
Respond to PG&E Environmental Monitor’s requests during construction.
2.1.8 MITIGATION MONITORING PROGRAM CONTACT LIST
A project contact list is included as Appendix B. This contact list includes the names of PG&E and
CPUC monitors, project managers, supervisory staff, and other members of the project team. The
list also includes phone numbers, fax numbers, and e-mail addresses where project members can
be reached during construction. The contact list will be updated periodically and redistributed to
the project team.
2.2 Responsibilities
2.2.1 MONITORING
As the lead agency under CEQA, the CPUC is required to monitor this project to ensure that the
required mitigation measures and APMs are implemented. The CPUC is responsible for ensuring
full compliance with the provisions of this monitoring program and has primary responsibility for
implementation of the monitoring program. As stated above, the CPUC has delegated monitoring
responsibilities to a third-party monitoring program. The CPUC EMs will be in field on a regular
basis, particularly when construction activities have the potential to impact a sensitive resource.
Responsible agencies, such as the USFWS, CDFG, and RWQCB may also elect to monitor
construction or conduct a site visit during construction.
Several mitigation measures require a qualified specialty monitor during construction. The
mitigation measures presented in Table 2.2-1 require that PG&E provides an on-site monitor.
PG&E may elect to have one or more full-time environmental monitors on-site on a daily basis to
coordinate specialty monitors, and to assist construction crews with interpreting mitigation
measures and correcting compliance problems in a timely manner. Environmental monitors would
also provide environmental training, as required, as new workers arrive on the project.
2.2.2 ENFORCEMENT The CPUC is responsible for enforcing the procedures adopted for monitoring through the CPUC
EMs assigned to each segment. The CPUC EMs shall note problems with monitoring, notify
designated project members, and report the problems to the CPUC Monitoring PM and PD, who
will then report problems to the CPUC Project Manager. The CPUC has the authority to stop or
redirect any construction activity associated with the Cabrillo-Santa Ynez 115 kV Reconductoring
Project, assuming it is safe to do so, if an activity poses an imminent threat or puts a sensitive
resource at undue risk beyond that already permitted (e.g., stopping a clearing crew from
unknowingly cutting coastal sage scrub in an exclusion area). The CPUC has assigned this
authority to the CPUC EMs in the field.
CHAPTER 2: ROLES AND RESPONSIBILITIES
Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-5
June 2010
Table 2.2-1: Required On-Site Monitoring
Mitigation Measure/
Applicant Proposed
Measure Number
Resource Monitor Project Area
MM AQ-1 Air Quality: Dust
Control Measure
General All, as needed
MM Bio-2 Sensitive Biological
Resources
Biological All, daily or as required in permits
MM Bio-5 Sensitive Plant
Species
Biological All, marking populations prior to
construction
MM Bio-6 Sensitive Amphibian
species
Biological Pull Site P4, P9, P10, P12, and P15;
Poles 11, 31, 33, 34, 48, 49, 68, 69, 70, 71,
72, 81, 82, 85, 86, 89, 90, 91, 112, 113,
114, and 115 68, 69, 70, 71, 114, 115, or
as otherwise required in permits
MM Bio-9 Sensitive Avian
Species
Biological Pull Site P1; Poles 4, 5, and 6
MM Bio-10 Active Burrowing
Owl Nests
Biological As needed where identified
MM Bio-12 Active Migratory
Bird or Raptor Nest
Biological As needed where identified
2.2.3 MITIGATION COMPLIANCE
PG&E is responsible for successfully implementing all the adopted mitigation measures in the
MMCRP. The MMCRP contains criteria that define whether mitigation is successful. Standards for
successful mitigation are also implicit in many mitigation measures that include such
requirements as obtaining permits or avoiding a specific impact entirely. Additional mitigation
success thresholds may be imposed by applicable agencies with jurisdiction through the permit
process.
PG&E shall inform the CPUC and its monitors, in writing, of any mitigation measures that are not
or cannot be successfully implemented. The CPUC, in coordination with its monitors, will assess
whether alternative mitigation is appropriate, and determine with PG&E the subsequent actions
required. If the measures are agency permit requirements, then the agency issuing the permit may
determine the appropriate action.
2.3 Communication
Communication is a critical component of a successful environmental compliance program. In
order to avoid project delays and possible shut-downs, environmental and construction
representatives must interact regularly and maintain professional, responsive communications at
all times. Similarly, PG&E representatives must coordinate closely with CPUC EMs to address and
CHAPTER 2: ROLES AND RESPONSIBILITIES
2-6 Mitigation Monitoring, Compliance, and Reporting Program
resolve issues in a timely manner. Section 2.3 of this MMCRP provides a communication protocol
to accurately disseminate information pertaining to on-going surveys and mitigation measures,
construction activities, contractors, and planned or upcoming work to all levels of the project.
Appendix C includes a communication protocol summary for use as quick reference, and to
supplement information provided in Section 2.3.
2.3.1 PRE-CONSTRUCTION KICK-OFF MEETING A pre-construction meeting was held on May 18, 2010 with the CPUC and PG&E team to review
the MMCRP and mutually agree upon the project’s communication protocol. Based on discussion
at the meeting and input from each party, Section 2 of this document was finalized and
incorporated into the MMCRP.
2.3.2 PROGRESS MEETINGS PG&E may request CPUC’s EM(s) to participate in regular field meetings to help resolve any issue
that may have arisen during the previous period and anticipate the upcoming activities.
Alternatively, PG&E or CPUC’s EM(s) may recommend a separate meeting to discuss mitigation,
variance requests, or other project related issues.
In addition to the progress meetings conducted at the field level, the PG&E Project Manager,
PG&E Construction Manager, PG&E EM, and the CPUC Monitoring PD and/or CPUC Project
Manager may participate in a weekly teleconference call to discuss project status.
2.3.3 DAILY COMMUNICATION Many of the issues that come up during construction can be resolved in the field through regular
communication between CPUC EMs, PG&E, and construction supervisors and contractors. Field
staff will be equipped with cell phones and available to receive phone calls at all times during
construction. A project contact list is included in Appendix B. The organization chart depicted in
Section 2.0 generally shows the lines of communication for use during construction. Additional
guidelines to ensure effective communication in the field are summarized below.
CPUC EM
The CPUC EM’s primary point of contact in the field is PG&E’s Lead Environmental Monitor. The
CPUC EM will contact PG&E’s Lead Environmental Monitor, if an activity is observed that
conflicts with one or more of the mitigation measures, to correct the situation. If the CPUC EM
cannot immediately reach PG&E’s Lead Environmental Monitor, then the Environmental Lead or
PG&E Project Environmental Manager will be contacted to address the problem. Similarly, the
CPUC EM will contact PG&E’s Lead Environmental Monitor for information on where
construction crews are working, the status of mitigation measures, and schedule forecasts. The
CPUC EM may discuss construction procedures directly with the construction contractors;
however, PG&E may require that their contractors defer questions to an onsite PG&E
representative. In all cases, the CPUC EM will contact the designated PG&E representative if a
problem is noted that requires action from the contractor.
The CPUC EM will not direct the contractor; however, the EM has the authority to stop or redirect
an on-going activity, assuming it is safe to do so, if an activity poses an imminent threat or puts a
CHAPTER 2: ROLES AND RESPONSIBILITIES
Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-7
June 2010
sensitive resource at undue risk beyond that already permitted (e.g., stopping a clearing crew from
unknowingly cutting coastal sage scrub in an exclusion area).
PG&E
PG&E will provide the CPUC Monitoring team with a list of construction monitoring personnel
and construction supervisory staff to contact regarding compliance issues. The contact list will
include each person’s title and responsibility, and will be updated as new project personnel are
assigned to the project and redistributed as necessary.
PG&E will prepare and distribute a weekly environmental compliance status report for
distribution to key project members, including the CPUC.
Any questions regarding the status of mitigation measures will be directed to the PG&E
Environmental Lead. The weekly environmental compliance status report will also be a tool to
keep all parties informed of construction progress and schedule changes.
2.3.4 COMMUNICATING COMPLIANCE ISSUES Section 3.1.2 below describes procedures to communicate concerns, incidents, and non-
compliances identified by the CPUC EMs during site inspections.
2.3.5 COORDINATION WITH OTHER AGENCIES
As discussed in Section 1.4, several local, state, and federal agencies have jurisdiction over portions
of the project. In addition, many of the mitigation measures were derived from specific permit
conditions or agency input. PG&E is responsible for contacting resource agencies and notifying
them of issues regarding their jurisdiction. The CPUC Monitoring team may request copies of
email correspondences, phone logs, or other documentation between PG&E and resource agencies
to avoid direct involvement from CPUC Monitoring PD or PM. However, if there is an unresolved
issue regarding compliance with a mitigation measure or permit requirement under the
jurisdiction of a resource agency, the CPUC Monitoring PD or PM may elect to contact the agency
with PG&E to discuss resolution, but only after having given PG&E sufficient time to address the
issue themselves. The CPUC Monitoring PD or PM will coordinate with PG&E prior to making
this call and provide PG&E with an opportunity to participate in the call.
2.3.6 DISPUTE RESOLUTION It is expected that the MMCRP will reduce or eliminate many potential disputes; however, even
with the best preparation, disputes may occur.
Issues should be first addressed at the field level informally between the CPUC EMs and
PG&E’s Environmental Monitors or Environmental Lead or at the regular progress meetings.
Questions may be raised to the PG&E Project Environmental Manager and the Environmental
Lead or PG&E Project Construction Manager. Should the issue persist or not be resolved at these
levels, the following procedures will be used.
Step 1 Disputes unresolved in the field and complaints (including those of the public) should be
directed to the CPUC Project Manager for resolution. The Project Manager will attempt to
resolve the dispute informally. Should this informal process fail, the CPUC Project Manager
will inform PG&E prior to initiating Step 2.
CHAPTER 2: ROLES AND RESPONSIBILITIES
2-8 Mitigation Monitoring, Compliance, and Reporting Program
Step 2 Should this informal process in the field fail, the CPUC Project Manager may issue a formal
letter requiring corrective actions to address the unresolved or persistent deviations from
the Proposed Project or adopted Mitigation Monitoring Program.
Step 3 If a dispute or complaint regarding implementation or evaluation of the Program or
mitigation measures cannot be resolved informally or through a letter request, any affected
participant in the dispute or complaint may file a written “notice of dispute” with the
CPUC’s Executive Director. This notice should be filed in order to resolve the dispute in a
timely manner, with copies concurrently served on other affected participants. Within 10
days of receipt, the Executive Director or designee(s) shall meet or confer with the filer and
other affected participants to resolve the dispute. The Executive Director shall issue an
Executive Resolution describing his/her decision, and serve it on the filer and other affected
participants.
Step 4 If one or more of the affected parties is not satisfied with the decision as described in the
Resolution, such party(ies) may appeal it to the Commission via a procedure to be specified
by the Commission.
Parties may also seek review by the Commission through existing procedures specified in the
CPUC Rules of Practice and Procedure for formal and expedited dispute resolution, although a
good faith effort should first be made to use the foregoing procedure.
Cabrillo-Santa Ynez 115 kV Reconductoring Project 3-1
June 2010
Chapter 3: Environmental Compliance and Field Procedures
3.1 Mitigation Measures Compliance and Reporting
3.1.1 PRE-CONSTRUCTION COMPLIANCE VERIFICATION In addition to performing various surveys and studies prior to construction, PG&E is required, by
the terms of the mitigation measures and the permitting requirements of various other regulating
agencies, to prepare plans and obtain approval of these documents. Copies of this documentation
will be retained by the CPUC third-party monitors, and provided to the CPUC with all files at the
completion of the project. The required plans, surveys, studies, and other documentation that
must be completed by PG&E before construction are listed in the Mitigation Measure/Applicant
Proposed Measure tables in Section 4.3.
While these documents are being reviewed by the approving agencies, they are also reviewed by
the CPUC. Compliance with all pre-construction mitigation measures and APMs presented will be
verified prior to construction, and construction may not start on any segment before PG&E
receives a written Notice to Proceed (NTP) from the CPUC Project Manager.
The CPUC third-party monitors, including Project Management staff and the technical experts,
will review all mitigation plans and reports and provide comments where applicable. Resource
agencies will also be involved in the review of applicable plans and reports. Where the MND calls
for CPUC review and approval of a plan or document, comments on these documents will be
provided to PG&E For required local and State agency permitting/consultations, the CPUC third-
party monitors will track PG&E’s progress as it relates to PG&E’s construction plans and project
mitigation and permitting requirements. Based on PG&E’s construction plans, CPUC may
authorize construction to begin on a phased basis, and the CPUC third-party monitors will handle
pre-construction compliance review accordingly. CPUC may issue NTPs for construction of each
phase separately, as soon as pre-construction compliance is satisfactorily accomplished for that
phase.
IMPORTANT: The CPUC will not authorize construction to begin until all pre-construction
requirements are fulfilled as appropriate for a given phase. To save time, PG&E should identify
any extra work space needs required for each phase of construction prior to the start of active
construction, so that these locations and their use can be included in the NTP. Refer to Section
3.2.1.
3.1.2 NOTICE TO PROCEED PROCEDURES The CPUC Project Manager and all IS/MND team reviewers will ensure that the Notice to Proceed
(NTP) process is consistent with the adopted CEQA document. The NTP approval(s) shall
document that pre-construction mitigation measure requirements, including applicable surveys
and studies, and project permit requirements have been met. In consideration of linear or phased
projects, more than one NTP can be requested for the Project. Each NTP request would be
applicable to a defined aspect or segment of construction. Construction is defined as any
CHAPTER 3: ENVIRONMENTAL COMPLIANCE AND FIELD PROCEDURES
3-2 Mitigation Monitoring, Compliance, and Reporting Program
mobilization activity which would move construction-related equipment and/or materials onto a
site. In some instances compliance with every requirement cannot be met prior to NTP issuance
and in such cases the NTP may be conditioned to define actions that will be undertaken and
documented prior to construction or prior to energizing the line.
Therefore, an NTP may be issued for a particular segment or project component upon compliance
with applicable mitigation measures and permits, and this process could occur in advance of
mitigation compliance for the entire project as a whole.
In general, an NTP request must include the following information:
A description of the work.
Detailed description of the segment location, including maps, photos, and/or other
supporting documents.
Verification that all mitigation measures and Applicant Proposed Measures are
implemented, or that they do not apply to the work covered by the NTP request.
Verification that all applicable permit conditions or requirements have been met for the
work covered by the NTP request.
In the case where some outstanding compliance items cannot be met prior to issuance of
the NTP, a request shall be submitted that outlines what submittals are outstanding, as
well as how they will be met and approved in a timely manner prior to construction.
Up-to-date biological resource surveys or a commitment to survey and submit results
prior to construction.
All applicable jurisdictional permits or agency approvals (if necessary).
Date of expected construction and duration of work.
CPUC/RMT will review the NTP request and pre-construction requirement submittals, in
accordance with the steps outlined below, to ensure that all of the information required to process
the approval is included.
1. PG&E submits NTP request.
2. CPUC/RMT will distribute the NTP request to the appropriate resource specialists and
reviewers to determine the completeness of the request, as applicable.
3. CPUC/RMT will also review and, if needed, will prepare a list of outstanding
requirements and where additional information or clarification is needed.
4. All questions and comments, as well as required additional information or clarifications,
will be sent to PG&E by CPUC/RMT in an e-mail.
5. PG&E will supply clarifications and/or additional information to be added to the NTP
request in a memo or letter format, along with responses addressing all comments and
questions forwarded by CPUC/RMT.
6. CPUC/RMT will complete a Compliance Status Table documenting compliance and any
outstanding requirements that can be made conditions of the NTP. If comments or
conditions are provided by CDFG, USFWS, Corps, and/or CCRWQCB, they will be
considered for incorporation into the NTP approval letter and compliance table.
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Cabrillo-Santa Ynez 115 kV Reconductoring Project 3-3
June 2010
7. RMT will prepare the draft NTP approval letter, which will document the scope of
work, compliance with IS/MND mitigation requirements, and list outstanding
conditions.
8. CPUC will review the draft NTP approval letter, and send the approval and an updated
compliance table to PG&E.
Please note that variance requests can be submitted with the NTP request for incorporation into
the NTP (please see Section 3.2.1 for variance submittal requirements).
3.1.3 COMPLIANCE VERIFICATION The CPUC EMs will conduct routine site visits to determine compliance with the mitigation
measures. Site visits will be coordinated with PG&E; at a minimum, the EMs will verify with
PG&E that access can be safely granted. Supplemental information provided by PG&E, including
pre-construction submittals, survey reports, weekly reports, meeting notes, and agency
correspondences, will also be used to verify compliance.
3.1.4 COMPLIANCE REPORTING
The CPUC EMs will document observations along the ROW through the use of field notes and
digital photography. In addition, field inspection forms will be utilized in the field to document
compliance of specific crews, construction activities, or resource protection measures. The forms
will provide a standardized checklist to facilitate inspections, as well as list mitigation measures
that were verified during the site visit. Information gathered from the inspection forms and field
notes will be used to generate weekly status reports and update the status of mitigation measures
listed in Section 4.3.
3.1.5 COMPLIANCE LEVELS Observations of issues or concerns that do not rise to the level of a non-compliance event, but that
if left uncorrected or repeated could result in a non-compliance event, should be noted and
provided to PG&E. These observations or concerns could also include minor deviations from a
permit condition or mitigation measure that do not affect the effectiveness of the mitigation
measures. Examples could include a trash bin that needs emptying, substitution of a coir roll for a
silt fence in the SWPPP measures that provides equivalent protection, a clarification to the
interpretation of a measure, a worker who was stopped before entering an exclusion zone for
which he did not know the footprint. These are typically issues or concerns that are addressed and
resolved at the field level.
A construction activity that deviates from permit conditions or mitigation measures and puts a
resource at un-permitted risk, would be considered a non-compliance. A noncompliance may also
be issued if a mitigation measure is not implemented according to the timing restrictions listed in
the mitigation table. Examples of non-compliances include, but are not limited to the actions listed
below.
Use of staging areas or extra workspace not identified in the MND or approved for use
during construction
Encroachment into an exclusion zone or sensitive resource area designated for
avoidance
CHAPTER 3: ENVIRONMENTAL COMPLIANCE AND FIELD PROCEDURES
3-4 Mitigation Monitoring, Compliance, and Reporting Program
Construction-related brush clearing outside the approved work limits
Construction-related grading, pole replacement, or line work without required
biological pre-construction surveys or a biological monitor onsite where and when
required
Improper installation of erosion or sediment control structures that cause unauthorized
release of sediments
Discharge of sediment laden pole hole water into a waterbody or storm drain
The CPUC EM will immediately notify the designated PG&E representative of a noncompliance
that requires immediate corrective action. A non-compliance memorandum will be sent to PG&E
by the CPUC Project Manager that outlines the incident, lists actions required to bring the activity
back into compliance, and provides a timeline for follow-up. If a construction activity or observed
resource protection measure only slightly deviates from project requirements and does not put a
resource at risk, the CPUC EM would instead issue an incident report to get the issue corrected.
Construction activities that could result in an incident report include, but are not limited to the
actions listed below.
Failure to properly maintain an erosion or sediment control structure, but the structure
remains functional
Use of an existing unapproved access road
Project personnel begin work on the ROW without proof of training
Work outside the approved work limits where the incident is within a previously
disturbed area, such as a gravel lot
Repeated incidents without addressing the issue may result in non-compliance.
3.2 Project Changes
At various times throughout the project, the need for extra workspace or additional access roads
may be identified. Similarly, changes to the project requirements (e.g., mitigation measures,
specifications, etc.) may be needed to facilitate construction or provide more effective protection of
resources. The project team should work together to find solutions when variations or adjustments
are necessary for specific field situations to avoid conflicts with adopted mitigation measures or
specifications.
3.2.1 VARIANCE PROCEDURE The CPUC Project Manager along with the CPUC Monitoring team will ensure that any variance
process or deviation from the procedures identified under the monitoring program is consistent
with CEQA requirements. No project variance will be approved by the CPUC if it creates new
significant impacts. A variance should be strictly limited to minor project changes that will not
trigger other permit requirements unless the appropriate agency has approved the change, that
does not increase the severity of an impact or create a new impact without appropriate agency
approval, and that complies with the intent of the mitigation measure.
CHAPTER 3: ENVIRONMENTAL COMPLIANCE AND FIELD PROCEDURES
Cabrillo-Santa Ynez 115 kV Reconductoring Project 3-5
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A proposed project change that has the potential for creating significant environmental effects will
be evaluated to determine whether supplemental CEQA review is required. Any proposed
deviation from the approved project, adopted mitigation measures, APMs, and correction of such
deviation, will be reported immediately to the CPUC Monitoring PD and PM for their review. The
CPUC Monitoring PD and PM will review the variance request to ensure that all of the
information required to process the variance is included and then forward the request to the
CPUC Project Manager for review and approval. The CPUC Project Manager may request a site
visit from the CPUC EM or need additional information to process the variance. In some cases, a
variance may also require approval by jurisdictional agencies. In general a variance request must
include the information listed below.
Detailed description of the location, including maps, photos, and/or other supporting
documents
How the variance request deviates from a project requirement
Biological resource surveys or verification that no biological resources would be
significantly impacted
Cultural resource surveys or verification that no cultural resources would be
significantly impacted.
Agency approval (if necessary)
A sample variance request form is included as Appendix D.
3.2.2 TEMPORARY EXTRA WORK SPACE PROCEDURES For the purposes of this MMCRP, Temporary Extra Work Space (TEWS) is defined as a work space
that would be utilized by PG&E during construction for a period of up to 60 days, and that was
not identified and evaluated during the CEQA process. Anything required to be utilized for a
period longer than 60 days will require a variance (see Section 3.2.1). PG&E must demonstrate
that: the TEWS is located in a disturbed area with no sensitive resources or land uses onsite or
adjacent to the proposed work space, PG&E has permission of the applicable landowner (e.g.,
municipality or private) to use the work space, and that use of the TEWS would not result in any
significant environmental impacts. In the event that PG&E determines a need for a construction
TEWS, it must submit such a request to the CPUC Monitoring PD. The CPUC Monitoring PD will
have the authority to approve or deny use of a TEWS, assuming it meets the criteria defined in the
previous paragraph. PG&E will not be permitted to use a TEWS prior to receiving written
authorization from the CPUC Monitoring PD. .
Following is a list of the specific information that PG&E would be required to submit with its
TEWS request:
Date of request;
Location of the TEWS (detailed description, including maps if required);
Property owner of TEWS;
An explanation of the necessity for the TEWS;
An analysis that demonstrates no new significant impacts would result from use of the
TEWS including: compaction contributing to runoff rates or other
CHAPTER 3: ENVIRONMENTAL COMPLIANCE AND FIELD PROCEDURES
3-6 Mitigation Monitoring, Compliance, and Reporting Program
stormwater/watershed effects; observed existing impacts to the site, such as old oil spills
or other potentially hazardous or polluting substances; abandoned vehicles, equipment
or other materials; or other sensitive resources;
Biological and botanical survey, especially for invasive plants, and mitigation for
invasive plants if present.
Duration and dates of expected use of the TEWS.
Details of the expected condition of the site after use.
A sample TEWS form is included as Appendix E.
3.3 Records Management
Any daily inspection and weekly status reports will be filed and used by the CPUC third-party
monitor to prepare a brief, final environmental compliance report following the completion of
construction. The final report will provide a discussion on how each mitigation measure was
implemented and include copies of submittals required for compliance. In addition, the success
criteria will be evaluated and used for future projects.
3.4 Public Access to Records
The public is allowed access to records and reports used to track the monitoring program.
Monitoring records and reports will be made available by the CPUC for public inspection on
request.
Cabrillo-Santa Ynez 115 kV Reconductoring Project 4-1
June 2010
Chapter 4: Mitigation Monitoring Program Table
4.1 Using the Table
The table in Appendix F lists the mitigation measures included in the Final IS/MND and the CPUC
decision (10-05-006) dated May 6, 2010. The Mitigation Monitoring Program table is the core
document for environmental requirements on the project, and is the primary guideline for
determining compliance with the MMCRP. A copy of the table should be kept with each crew
working on the ROW, and all supervisory staff working on the project should be familiar with its
contents.
The CPUC will use a modified version of the mitigation measure tables during the preconstruction
planning and construction monitoring phases of the project to accurately track the status of
mitigation measures. Tables will be sorted and divided into pre-construction measures and
measures to be implemented during construction. Similarly, a separate table listing mitigation
measures that require CPUC approval may be generated. The modified tables will also include a
status column that will be updated on a regular basis.
4.2 Effectiveness Review
The CPUC may conduct a comprehensive review of conditions which are not effectively
mitigating impacts, at any time it deems appropriate, including as a result of the Dispute
Resolution procedure outlined in Section 2.3.6. If the Commission determines that any conditions
are not adequately mitigating environmental impacts caused by the project, then the Commission
may, in coordination with PG&E, develop alternative measures to effectively mitigate these
impacts. These reviews will be conducted in a manner consistent with the Commission’s rules and
practices.
CHAPTER 4: MITIGATION MONITORING PROGRAM TABLE
4-2 Mitigation Monitoring, Compliance, and Reporting Program
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Appendix A: Project Segment Maps
APPENDIX A: PROJECT SEGMENT MAPS
Cabrillo-Santa Ynez 115 kV Reconductoring Project A-1
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APPENDIX A: PROJECT SEGMENT MAPS
A-2 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
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June 2010
APPENDIX A: PROJECT SEGMENT MAPS
A-4 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
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APPENDIX A: PROJECT SEGMENT MAPS
A-6 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
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APPENDIX A: PROJECT SEGMENT MAPS
A-8 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
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APPENDIX A: PROJECT SEGMENT MAPS
A-10 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
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APPENDIX A: PROJECT SEGMENT MAPS
A-12 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
Cabrillo-Santa Ynez 115 kV Reconductoring Project A-13
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APPENDIX A: PROJECT SEGMENT MAPS
A-14 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
Cabrillo-Santa Ynez 115 kV Reconductoring Project A-15
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APPENDIX A: PROJECT SEGMENT MAPS
A-16 Mitigation Monitoring, Compliance, and Reporting Program
APPENDIX B: PROJECT SEGMENT MAPS
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APPENDIX A: PROJECT SEGMENT MAPS
A-18 Mitigation Monitoring, Compliance, and Reporting Program
Appendix B: Project Contact List
APPENDIX B: PROJECT CONTACT LIST
Cabrillo-Santa Ynez 115 kV Reconductoring Project B-1
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Project Contact List
Name Agency/
Company
Job Title/Duties Phone Number/Fax
Number
Email Address
Billie Blanchard CPUC CPUC Project Manager (415) 703-2068 (office) [email protected]
Jo Lynn Lambert PG&E Attorney (909) 793-4942 (office)
(909) 528-6436 (cell)
(415) 973-5248 (PG&E)
Sam Danner PG&E Land Planner (805) 305-7489 (cell)
(805) 546-3836 (office)
Lee Ellis PG&E PG&E Project Construction Manager (805) 260-9331 (office) [email protected]
Jeff Glenn PG&E PG&E Construction Management
Jim Layugan PG&E PG&E Construction Management
Colleen Taylor CH2M Hill Environmental Lead (510) 587-7644 (office)
(510) 316-7406 (cell)
Nicole McNair ETIC SWPPP Lead (925) 602-4710 x 44 (office)
(925) 408-6616 (cell)
TBD ETIC SWPPP Monitor
Christophe Descantes PG&E Cultural Lead (415) 973-1177 (office)
(925) 719-2740 (cell)
Rick Hernandez PG&E Hazardous Material Lead (805) 595 6376 (office)
(805) 441 6408 (cell)
TBD Garcia and
Associates
Environmental Monitors
Brent Miyazaki RMT CPUC Monitoring Project Director (323) 337-6513 (cell) [email protected]
APPENDIX B: PROJECT CONTACT LIST
B-2 Mitigation Monitoring, Compliance, and Reporting Program
Project Contact List (Continued)
Name Agency/
Company
Job Title/Duties Phone Number/Fax
Number
Email Address
Bonny O’Connor RMT CPUC Monitoring Project Manger (650) 373-1200 (office) [email protected]
Charina Gaspay RMT CPUC Environmental Monitor (650) 373-1200 (office) [email protected]
Aaron Lui RMT CPUC Environmental Monitor (650) 373-1200 (office) [email protected]
Logan Wicks RMT CPUC Environmental Monitor (213) 458-5660 (cell) [email protected]
Appendix C: Communication Protocol Summary
APPENDIX C: COMMUNICATION PROTOCOL SUMMARY
Cabrillo-Santa Ynez 115 kV Reconductoring Project C-1
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Section 2.3 of the Mitigation Monitoring, Compliance and Reporting Program (MMCRP) includes
a communication protocol to ensure that CPUC Environmental Monitors (CPUC EMs) have access
to project information, including schedules, mitigation measure status, and survey results. The
communication protocol was also developed to establish a chain of command that will be used to
report environmental issues observed during CPUC EM site inspections. The following table
provides an outline of the communication protocol. For additional information, refer to Sections
2.0 and 3.0 of the MMCRP.
Table C-1: Communication Protocol
Action Item Responsibility Primary
Contact
Secondary
Contact/
Participants
Description
Meetings
Regular
Construction
Meetings
PG&E CM CPUC’s EM TBD Regular construction meetings to
be held in the field to discuss
construction progress and
construction and environmental
issues. Refer to Section 2.3.2 of
the MMCRP.
Bi-Weekly
Teleconference
Calls
CPUC
Monitoring PD
CPUC PM CPUC
Monitoring
PM
CPUC EMs
PG&E CM
PG&E PM
PG&E EMs
Bi-weekly teleconference call to
discuss status of mitigation
measures, construction schedule,
issues noted during site visits,
and project changes.
Field Meetings PG&E or
CPUC EMs
TBD TBD Field meetings may be requested
by any party to discuss variance
requests, non-compliances, or
other site-specific issues.
Project Changes
Scheduling PG&E PM CPUC
Monitoring
PM
CPUC EMs Changes in project schedule that
could affect the status of
mitigation measures will be
communicated to the CPUC
Monitoring PM by email. If the
project change would have an
immediate impact, the CPUC
EM or will be contacted by
phone.
APPENDIX C: COMMUNICATION PROTOCOL SUMMARY
C-2 Mitigation Monitoring, Compliance, and Reporting Program
Table C-1 (Continued): Communication Protocol
Action Item Responsibility Primary
Contact
Secondary
Contact/
Participants
Description
Variance
Requests
PG&E PM or
Environmental
Lead
CPUC
Monitoring
PM
CPUC
Monitoring
PD and CPUC
PM
All variance requests will be
submitted to the CPUC
Monitoring PM through the
variance request form and
supporting documentation. The
CPUC Monitoring PM will
forward the variance request to
the CPUC PM and CPUC
Monitoring PD after verifying
the information is complete. The
CPUC PM will distribute a
variance request approval or
denial after review is complete.
Refer to Section 3.2.1 of the
MMCRP.
Compliance Issues
Minor Incidences
and Non-
compliance
CPUC EM or
CPUC
Monitoring PM
PG&E PM or
Environmental
Lead
PG&E TBD Minor incidences and non-
compliances noted during site
inspections will be documented
by the CPUC EMs and sent to
PG&E for corrective action.
Notification of a minor incident
or non-compliance will occur no
later than the following day. If
PG&E corrects the issue before
the report is issued, it will be
noted in the report. Refer to
Section 2.3.6 of the MMCRP.
General
Concerns
CPUC EMs PG&E EM PG&E (TBD) The CPUC EMs will contact
PG&E EMs to discuss general
issues and questions that come
up during site visits. The CPUC
may talk with other crew
members on the ROW, but will
not direct their work or rely on
them for information regarding
the project.
Agency
Jurisdiction
Concerns
PG&E PM Applicable
Agency
CPUC
Monitoring
PM
The resource agencies will be
notified by PG&E of any issues
regarding their jurisdiction. The
CPUC Monitoring PM will also
APPENDIX C: COMMUNICATION PROTOCOL SUMMARY
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Table C-1 (Continued): Communication Protocol
Action Item Responsibility Primary
Contact
Secondary
Contact/
Participants
Description
receive immediate notification.
Communication between PG&E
and resource agencies will be
documented and submitted to
the CPUC Monitoring PM.
In addition, if the CPUC
Monitoring PM have an
unresolved concern about
compliance with agency
requirement, they will request to
participate in a call with PG&E
and the resource agency.
Dispute
Resolution
All CPUC
Monitoring
PM or PD
CPUC PM In the event that a dispute
cannot be resolved in the field,
the CPUC Project Manager may
issue a formal letter. Refer to
Section 2.3.6 of the MMCRP.
APPENDIX C: COMMUNICATION PROTOCOL SUMMARY
C-4 Mitigation Monitoring, Compliance, and Reporting Program
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Appendix D: Variance Request Form
APPENDIX D: VARIANCE REQUEST FORM
Cabrillo-Santa Ynez 115 kV Reconductoring Project D-1
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Variance Request No.:
Environmental Variance Request Form
Cabrillo – Santa Ynez 115kV Reconductoring Project
Date: Date by which Approval is Required:
Location: Current Land Use:
Ownership: Private County Road: Other:
Drawing/Plan No.: Drawing/Sketch Attached? Yes No
Variance Summary Description:
Describe variance in detail:
Reason for the variance:
----------------------------------------------------------------------------------------------------------------------------------
This part to be completed by Environmental Monitor
Botanical Survey Required? Yes No
If yes, results of survey: Survey Date:
If no, explain why survey not needed:
Survey report attached? Yes No Submitted separately by (date)
Wildlife Survey Required? Yes No
If yes, results of survey: Survey Date:
If no, explain why survey not needed:
Survey report attached? Yes No Submitted separately by (date)
Cultural or Paleontology Resource Survey Required? Yes No
If yes, results of survey: Survey Date:
If no, explain why survey not needed:
Survey report attached? Yes No Submitted separately by (date)
APPENDIX D: VARIANCE REQUEST FORM
D-2 Mitigation Monitoring, Compliance, and Reporting Program
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Appendix E: Temporary Extra Work Space Form
APPENDIX E: TEMPORARY EXTRA WORK SPACE FORM
Cabrillo-Santa Ynez 115 kV Reconductoring Project E-1
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Date: Requested Date of Approval: Prepared by:
Location/Address:
Proposed Use of Site:
Proposed Date(s) of Use Proposed Hours of Use:
Note: Proposed Dates of Use must be less than 60 days or a Variance Request will be required.
Adjacent Land Uses:
Biological, Cultural and Paleontological reconnaissance surveys are mandatory for use of any
areas containing vegetation, or exposed earth that have not been previously surveyed and fully
described in project documents. Biological surveys are mandatory for all temporary extra work
sites. Attach a diagram of the proposed area that identifies the location of the site and proximity to
sensitive resources or receptors.
Complete the Environmental Checklist below.
Note: Yes answers require additional clarification and should be submitted as an attachment to this form.
Environmental Checklist Yes No CPUC Verified
Air Quality: Would equipment be on site or idled for more than 10
minutes? Would there be dust-producing activities?
Biological Resources: Would use of the site result in potential impacts to
sensitive biological resources? Would use of the site result in potential
for the spread of noxious weeds?
Cultural/Paleontological Resources: Would clearing or grading be
required?
Water Resources: Would runoff from the site flow into storm drains or a
waterway? Would equipment refueling or maintenance be performed?
Would materials block/impact storm drains or gutters?
Land Use and Recreation: Would use of site block access to local land
uses and recreational areas?
Noise: Are noise-sensitive receptors (e.g., homes, schools, hospitals,
churches convalescent homes, parks, recreational areas) adjacent to the
site?
Socioeconomics: Would access to business be blocked? Would there be
disruption of business operations?
Traffic: Would parking be eliminated? Would increased construction
traffic result in impacts? Is the site a residential area?
Visual: Would lights at site create glare for adjacent land uses (including
roadways)?
APPENDIX E: TEMPORARY EXTRA WORK SPACE FORM
E-2 Mitigation Monitoring, Compliance, and Reporting Program
Standard Conditions of Approval
The CPUC, via its designated Environmental Monitor, will review and approve/deny
the Temporary Extra Workspace Request (TEWS) request within four business days of
receiving this completed form.
Use of TEWS is limited to 60 days. First proposed date of use:
Use of TEWS shall be in compliance with local ordinances (including traffic/noise) and
mitigation measures.
If any signs of cultural resources are identified, work shall cease immediately and the
site shall be reevaluated.
The proposed site shall not be used for storage of fuel or hazardous materials.
All drips, leaks, and/or spills from vehicles and/or equipment shall be cleaned-up
immediately and disposed of in appropriate, labeled containers.
Adjacent streets shall be swept or cleaned with water at the end of each workday if
visible soil material is carried on them.
No parking or storage of vehicles (including personnel vehicles), equipment, pipe, or
any other project- related item shall be allowed on adjacent roadways.
If a complaint is received, it shall be forwarded to the PG&E Permit Coordinator, the
CPUC EM, and the CPUC Monitoring PD for review.
The following signatures indicate that the proposed site is approved for TEWS. On a random
basis, a CPUC EM will verify that use of the proposed site is in accordance with the conditions
noted. This approval may be revoked at any time by any one of the approval team. Failure to
comply with all conditions will result in immediate revocation of this TEWS approval.
Property Owner: Date:
PG&E Construction: Date:
PG&E Permit Coordinator: Date:
The above TEWS request and attached documentation have been reviewed and this request is
approved or denied (circle one).
CPUC Monitoring Project Director: Date:
Additional CPUC Conditions of Approval
(CPUC Monitor Initial ______)
Reason(s) for Denial
Appendix F: Mitigation Monitoring Program Table
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-1
June 2010
Mitigation Monitoring Program Table
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
APM AE-1 APM Aesthetics (AE)-1: New source of substantial light or glare avoidance. PG&E will
replace the existing conductor with a non-specular conductor for the specific purpose of
minimizing the reflectivity of any new project facilities.
Verify equipment
through on-site
monitoring or photo
documentation.
During construction
APM LU-1 APM Land Use (LU)-1: Agriculture impacts avoidance. To avoid potential impacts to
agriculture, PG&E will work with farmers and ranchers to conduct its work between their
harvest and planting periods where and whenever possible. In areas containing permanent
crops (i.e., grape vines, tree orchard, etc.) that must be removed and replaced to gain
access to poles sites for construction purposes, PG&E will provide compensation to
landowners for crop loss and other reasonable and associated costs as soon as practicable
after completion of construction. Access across active crop areas will be negotiated with
the owners in advance of any construction activities
Verify coordination
with landowners
through
documentation
During construction
APM AQ-1 Mitigation Measure AQ-1 (Proposed to supersede APM AQ-1): The following fugitive
dust control measures would be implemented unless otherwise approved by the
SBCAPCD. Copies of the finalized dust control measures would be submitted to the CPUC
for recordkeeping.
PG&E would use water trucks or sprinkler systems during
construction on all active construction and disturbed areas to keep
areas of vehicle and equipment movement sufficiently damp to
prevent dust from leaving the site. At a minimum, this would include
wetting down these areas in the late morning and after work is
completed for the day. Watering frequency would increase whenever
the wind speed exceeds 15 miles per hour (mph).
Reclaimed water will be used whenever possible; however, reclaimed
water will not be used in or around crops for human consumption.
Confirm the CPUC
has received the
name and telephone
number(s) of the
designated
monitor(s) for the
Dust Control
Program
Prior to construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-2 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
Construction equipment and related vehicles, including personal
vehicles, would be limited to a maximum speed of 15 mph on
unpaved roads
All exposed soil stockpiles (e.g., soil and sand) would be covered.
Gravel pads, bamboo mats, or a suitable equivalent would be installed
at all access points to prevent tracking mud on to public roads, as
discussed in the project’s Stormwater Pollution Prevention Plan
(SWPPP)
PG&E would designate a person or persons to monitor the dust
control program and to order increased watering, as necessary, to
prevent dust transport off site. Monitor duties would include holiday
and weekend periods when work may be in progress. The name and
telephone number of the monitor would be provided to the SBCAPCD
prior to project construction
Verify
implementation of
measures through
on-site monitoring
and During
construction
documentation from
Dust Control
Program designated
monitor.
Verify obtainment of
finalized dust control
measures through
documentation.
During construction
APM GHG-1 APM Greenhouse gas (GHG)-1: GHG emissions minimization. The following measures
will be implemented during construction to minimize GHG emissions.
Park-and-ride facilities in the Project vicinity will be identified and construction workers
will be encouraged to carpool to the job staging area to the extent feasible. The ability to
develop an effective carpool program for the Proposed Project will depend upon the
proximity of carpool facilities to the staging area, the geographical commute departure
points of construction workers, and the extent to which carpooling will not adversely affect
worker arrival time and the Project’s construction schedule. Crew transportation to the
Project site is discussed in Section 4.10, Traffic and Transportation.
Unnecessary construction vehicle idling time will be minimized. The ability to limit
construction vehicle idling time is dependent upon the sequence of construction activities
and when and where vehicles are needed or staged. Certain vehicles, such as large diesel
Verify
implementation of
measures through
on-site monitoring
and documentation
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-3
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
powered vehicles, have extended warm-up times following start-up that limit their
availability for use following startup. Where such diesel powered vehicles are required for
repetitive construction tasks, these vehicles may require more idling time. The Proposed
Project will apply a “common sense” approach to vehicle use; if a vehicle is not required
for use immediately or continuously for construction activities, its engine will be shut off.
Construction foremen will include briefings to crews on vehicle use as part of pre-
construction conferences. Those briefings will include discussion of a “common sense”
approach to vehicle use.
Construction equipment will be maintained in good working order, per manufacturing
specifications. Low-emission construction equipment will be used where feasible to further
minimize the minimal short-term increase in GHG emissions. With implementation of
APM GHG-1, the entire construction effort for this project is forecasted to create 379 metric
tons of CO2 which represents a small fraction of the emissions limit set by AB322020 (427
million metric tons CO2e).
APM BO-1 APM Biological Resources (BO)-1: General avoidance of biological resources impacts.
Litter and trash management. All food scraps, wrappers, food containers, cans, bottles, and
other trash from the Project area will be deposited in closed trash containers. Trash
containers will be removed from the Project area at the end of each working day.
Verify
implementation of
measures through
on-site monitoring
and documentation
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-4 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
Parking. Vehicles and equipment will be parked on pavement, existing roads, and
previously disturbed or developed areas or work areas as identified in this document. Off-
road parking shall only be permitted in previously identified and designated work areas.
Route and speed limitations. Vehicles will be confined to established roadways and pre-
approved access roads, overland routes and access areas. Access routes and temporary
work areas will be limited to the minimum necessary to achieve the Project goals. Routes
and boundaries of work areas, including access roads, will be clearly mapped prior to
initiating Project construction. Vehicular speeds will be kept to 15 mph on unpaved roads.
Maintenance and refueling. All equipment will be maintained such that there will be no leaks
of automotive fluids such as fuels, solvents, or oils. All refueling and maintenance of
vehicles and other construction equipment will be restricted to designated staging areas
located at least 100 feet from any down gradient aquatic habitat unless otherwise isolated
from habitat. Proper spill prevention and cleanup equipment shall be maintained in all
refueling areas.
Minimization of fire hazard. During fire season in designated State Responsibility Areas, all
motorized equipment driving off paved or maintained gravel/dirt roads will have federal
or state approved spark arrestors. All off-road vehicles will be equipped with a backpack
pump filled with water and a shovel. All fuel trucks will carry a large fire extinguisher
with a minimum rating of 40 B:C, and all equipment parking and storage areas will be
cleared of all flammable materials.
Pets and firearms. No pets or firearms will be permitted at the Project site.
Verify
implementation of
measures through
on-site monitoring
and documentation.
During operation
APM BO-2 APM BO-2: Avoidance of impacts to natural habitats
Minimization of grading and vegetation removal along access roads and pole work areas.
Clearing and grading will be limited to previous access roads that have become overgrown
with vegetation. Overland access routes and work areas around pole locations will not
require any grading or vegetation removal other than minimal tree trimming as described
Verify
implementation of
measures through
on-site monitoring
and documentation
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-5
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
in the Project description.
Tree removal. A single tree, a Leland Cypress, is planned for removal as described in the
Project description. No other tree removal is planned.
Re-vegetation. Since clearing and grading is limited to re-establishment of existing roads,
no re-vegetation is needed for the Project. Temporarily disturbed vegetation is expected to
recover without the need for reseeding.
APM BO-4 APM BO-4: General avoidance and minimization of impacts to aquatic or wetland
habitat.
Timing and extent of work in aquatic or wetland habitat. Work in aquatic or wetland
habitat is limited to the removal of two poles and replacement of one pole in the wetland
northeast of SR 246. All ground-disturbing work at this location will take place in dry
conditions. The timing is dependent on seasonal rainfall; in winter 2008-2009, ground was
dry even in January.
Verify construction
activities through on-
site monitoring and
documentation
During construction
in wetland or
aquatic habitat
APM BO-5 APM BO-5: Avoidance of impacts to California red-legged frog, California tiger
salamander, western spade foot toad and western pond turtle in proximity to identified
suitable breeding ponds or aquatic habitat.
Dawn and dusk timing restrictions. Construction activities within 600 feet of suitable
aquatic habitat shall not begin prior to 30 minutes after sunrise and will cease no later than
30 minutes before sunset.
Erosion control materials. Only tightly woven netting or similar material shall be used for
all geo-synthetic erosion control materials such as coir rolls and geo-textiles. No plastic
monofilament matting will be used.
Confirm construction
time requirements for
aquatic habitat.
Ensure netting
material is made of
suitable material
Prior to construction
Confirm construction
time requirements for
aquatic habitat.
Ensure netting
material is made of
suitable material
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-6 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
APM BO-9 Avoidance of and minimization of potential impacts to wetlands and water resources.
Stormwater Pollution Prevention Plan and erosion control measures. As described in
Section 4.8, APMs WQ-1 and WQ-3, a Stormwater Pollution Prevention Plan (SWPPP) will
be developed that describes sediment and hazardous materials control, fueling and
equipment management practices, and other factors deemed necessary for the Project.
Erosion control measures will be implemented where necessary to reduce erosion and
sedimentation in wetlands, waters of the United States, and waters of the state, as well as
aquatic habitat occupied by sensitive species. Erosion control measures will be monitored
on a regularly scheduled basis, particularly during times of heavy rainfall. Corrective
measures will be implemented in the event erosion control strategies are inadequate.
Sediment/erosion control measures will be continued at the Project site until such time that
soil stabilization is deemed adequate. Brush or other similar debris material will not be
placed within any stream channel or on its banks. No Project work activity is planned
within the limits of any stream channel.
Verify required
contents in the
SWPPP
Prior to construction
Verify SWPPP and
erosion control
measure are being
implemented
correctly through on-
site monitoring and
documentation.
Verify that
supplementary
measures are being
implemented as
necessary through
on-site monitoring.
During construction
MM Bio-1 Mitigation Measure Bio-1 (Proposed to supersede APM BO-1 “Development and
implementation of a Worker Environmental Awareness Program”): A qualified biologist
would conduct an environmental awareness program for all construction and on-site
Verify required
contents in the
WEAP.
Prior to construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-7
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
personnel prior to the beginning of construction activities. Training would include the
following topics and information:
A discussion of avoidance and minimization measures being implemented to protect
biological resources as well as the terms and conditions of the Biological Opinion and other
permits.
A map depicting all of the locations of previously flagged/marked sensitive and special
status plants. The map would be accompanied with an explanation of how the locations
were demarcated out in the field.
Information on the federal and state Endangered Species Acts, as well as other applicable
state and federal laws protecting sensitive plant and wildlife species, nesting birds,
wetlands, and other water resources. The consequences of noncompliance with these acts
and laws would be disclosed to the workers.
Information about the presence, life history, defining characteristic, and habitat
requirements of all special-status species with a potential to be affected within the project
area.
An educational brochure would be produced for construction crews working on the
project. The brochure would include color photos of sensitive species as well as a
discussion of mitigation measures.
Verify all
construction and on-
site personnel have
undergoing training
through
documentation and
on-site monitoring.
During Construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-8 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
MM Bio-2 Mitigation Measure Bio-2 (Proposed to supersede APM BO-1 “Biological monitor on-
site during construction activities in sensitive areas” and “Reporting and
communication”): A qualified biological monitor would be on site during all ground-
disturbing construction activities in or near sensitive habitats previously identified by a
qualified biologist. The monitor would ensure implementation of and compliance with all
avoidance and mitigation measures. The monitor would have the authority to stop work or
determine alternative work practices in consultation with agencies and construction
personnel as appropriate if construction activities are likely to impact sensitive biological
resources. The biological monitor would document monitoring activities in daily logs to
document construction activities and environmental compliance. The daily logs would be
included in the project report submitted to the appropriate agencies following completion
of construction.
The biological monitor would be responsible for reporting any capture and relocation,
harm, entrapment, or death of a listed species to the USFWS and/or the CDFG and for
reporting any permit violations in a timely manner and as indicated in their respective
permits. Weekly monitoring reports would be submitted to CPUC, and to any resource
agencies (upon request), throughout construction. A final project summary report would
be submitted to the CPUC 90 days after the completion of construction activities.
Confirm
qualifications of the
monitor
Prior to construction
Verify biological
monitoring through
daily logs and
reports.
During construction
MM Bio-3 Mitigation Measure Bio-3 (Proposed to supersede APM BO-1 “Identification and
marking of sensitive resource areas”): Sensitive resources identified during pre-
construction surveys in the project vicinity would be mapped and clearly marked in the
field. Such areas would be avoided during construction to the extent practicable and/or
additional measures specific to sensitive species types as described herein and that may be
required by the USACE, FWS, CDFG, and RWQCB permits, would be implemented to
avoid or minimize impacts.
Verify that sensitive
areas are clearly
marked and avoided
through on-site
monitoring.
During construction
MM Bio-4 Mitigation Measure Bio-4 (Proposed to supersede APM BO-2 “Weed management”):
All project vehicles would be washed before arrival on site at PG&E’s Santa Maria,
Verify vehicles are
washed thoroughly
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-9
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
Lompoc, or Buellton PG&E wash facilities or otherwise approved wash-down location.
Vehicles would also be cleaned at an appropriate wash facility, at the completion of the
project or when off-road use for that vehicle has been completed.
prior to arriving on-
site and at the
completion of use on-
site through on-site
monitoring.
MM Bio-5 Mitigation Measure Bio-5 (Proposed to supersede APM BO-3 “Avoidance of and
minimization of potential impacts to special-status plants”): A pre-construction survey
would be conducted by a qualified botanist or biologist prior to commencement of
construction in each area. All rare plant populations would be appropriately marked or
flagged for exclusion, or as appropriate, the limits of construction will be marked between
the population and the work area. Surveys and marking or flagging must be completed no
more than 30 days prior to construction. In the event that any previously unidentified
listed plants, or CNPS List 1-3 plants cannot be avoided, PG&E would consult with the
USFWS and/or the CDFG (depending on whether the species is on the federal or state list
of sensitive species) to determine appropriate measures to minimize effects to the species
and its habitat during construction of the project, as well as during operation and
maintenance. The CPUC would be informed of the results of any agency consultations.
Verify the completion
of survey through
documentation.
Verify necessary
marking or flagging
through photo
documentation or on-
site visit.
Verify any necessary
agency consultations
through
documentation.
No more than 30
days prior to
construction
Verify that sensitive
plants are clearly
marked and avoided
through on-site
monitoring.
Verify agency
consultations, if
necessary, through
documentation.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-10 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
MM Bio-6 Mitigation Measure Bio-6 (Proposed to supersede APM BO-5 “Pre-construction surveys
and relocation of species”): Pre-construction surveys for special-status amphibians and
aquatic reptiles would be conducted no more than two weeks prior to the commencement
of construction. Surveys would include work areas within 600 feet of suitable CTS
breeding habitat and work areas within 300 feet of suitable CRLF aquatic habitat. Surveys
would be conducted by a qualified, agency-approved biologist. Potential habitat for
western spade foot toad and western pond turtle exists in similar locations to those for
CRLF and CTS. The biologist would relocate any special-status species to a location
previously agreed upon by the USFWS and the CDFG. Before the start of work each
morning, the biologist would check under any equipment and stored construction supplies
left in the work area overnight within 600 feet of suitable habitat. All pole holes would be
backfilled or covered at the end of the work day to prevent entrapment of special-status
species.
Verify the completion
of survey through
documentation.
No more than 2
weeks prior to
construction in
suitable habitat
buffer.
Verify daily
biological sweep of
work area within
suitable habitat
through
documentation and
on-site monitoring.
During construction
MM Bio-7 Mitigation Measure Bio-7 (Proposed to supersede APM BO-5 “Seasonal timing
restrictions”): All ground-disturbing construction activities within 600 feet of suitable
habitat for CFLF, CTS, western spade foot frog, and western pond turtle would be limited
to May 1 through October 31, to the greatest extent feasible. For work in these areas, a
qualified biologist would conduct a pre-construction survey of the work area immediately
preceding construction activities. All potential habitat areas including burrows, woody
debris piles, wetlands, riparian areas, and edges of ponds within the work area would be
thoroughly checked. Any special-status species found would be captured and relocated to
a FWS and CDFG approved location type (e.g., a small mammal burrow) and area, prior to
the start of construction.
Verify the completion
of survey through
documentation.
Immediately prior to
construction in
suitable habitat
buffer.
Verify construction
activities to only
occur during May1 to
October 31within
suitable habitat
through on-site
monitoring and
documentation.
During construction
MM Bio-8 Mitigation Measure Bio-8 (Proposed to supersede APM BO-5 “Minimization of burrow
disturbance”): Plywood sheets would be used to temporarily cover potentially active
Verify plywood
sheets are used to
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-11
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
burrows in work areas within 600 feet of suitable breeding habitat. Burrows would be
covered after re-location has taken place, if necessary, or otherwise specified in the
Biological Opinion.
cover potentially
active burrows after
relocation or in
accordance to BO
protocol through
documentation and
on-site monitoring.
MM Bio-9 Mitigation Measure Bio-9 (Proposed to supersede APM BO-6 “Avoidance of and
minimization of potential impacts to southwestern willow flycatcher and least Bell’s
vireo”): Work anticipated within 300 feet of the potential nesting habitat for these species
and the designated critical habitat for southwestern willow flycatcher includes the use of
pull site P1 and insulator replacement at Poles 4, 5, and 6. Insulator replacement and use of
the pull site would be restricted to the non-nesting season. For the purposes of this
measure, the nesting season for these species is considered to be March 15 to September 15.
Additionally, the raptor nesting season extends from February 1 through August 15. Work
within the period of February 1 to September 15 in this area would only occur if pre-
construction surveys determine these species are not actively nesting within 300 feet of the
work areas, or a qualified biologist is present during all activities to monitor for potential
nest disturbance per an Avian Protection Plan as described in Mitigation Measure Bio-12.
Verify the completion
of survey through
documentation.
Prior to construction
Verify construction
activities to only
occur during
September 16 to
January 31 to within
critical habitat
through on-site
monitoring and
documentation.
Verify results of
preconstruction
surveys through
documentation to
allow work to occur
from January 31
through March 14.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-12 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
MM Bio-10 Mitigation Measure Bio-10 (Proposed to supersede APM BO-7 “Avoidance of and
minimization of potential impacts to western burrowing owl”): The following methods
would be employed unless otherwise approved by CDFG or USFWS. Pre-construction
burrowing owl surveys would be conducted by a qualified biologist within 250 feet of
areas within burrowing owl habitat subject to disturbance. Burrowing owl surveys would
follow the CDFG’s Burrowing Owl Protocol Survey and Mitigation Guidelines (California
Burrowing Owl Consortium 1993) and shall occur between February 1 and September 30.
If ground-disturbing activities are delayed or suspended for more than 30 days after the
pre-construction surveys, the site would be resurveyed. If no burrowing owls are
detected, no further mitigation is necessary.
Appropriate avoidance, minimization, or protection measures shall be determined in
consultation with CDFG in the event that construction is located within 150 feet of
occupied burrows or nests during the non-breeding season, or within 250 ft of an area
Verify the completion
of survey through
documentation.
Verify PG&E’s
consultation for
appropriate
mitigation with
CDFG if burrowing
owls are detected.
30 days prior to
construction in
suitable habitat
buffer.
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-13
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
subject to disturbance during the breeding season. Measures could include, but would not
be limited to the following:
No disturbance would occur within approximately 160 feet (50 meters) of occupied
burrows during the non-breeding season of September 1 through January 31, or within
approximately 250 feet (75 meters) during the breeding season of February 1 through
August 31
The limits of the exclusion zone in the project work area would be clearly marked with
signs, flagging and/or fencing
If work within these limits is unavoidable while burrows are active, work would only take
place within the presence of a qualified monitor who would monitor to determine if the
owls show signs of disturbance or, upon prior approval from CDFG a passive relocation
effort (displacing the owls from the work area) may be conducted as described below, and
subject to the approval of the CDFG.
Passive relocation of owls may occur during the non-breeding season (September 1
through January 31) with prior approval from CDFG. Passive relocation would include
installing one-way doors on the entrances of burrows. The one-way doors would be left in
place for 48 hours to ensure the owls have vacated the nest site. Owls would not be
relocated during the breeding season.
Verify appropriate
buffers and/or on-site
monitors are
established.
During construction
surrounding an
active burrow or
nest
MM Bio-11 Mitigation Measure Bio-11: The open ends of light-duty steel poles would be covered
during storage to prevent burrowing owls or any other sensitive species from inhabiting
the pole openings.
Verify pole ends are
covered through on-
site monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-14 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
MM Bio-12 Mitigation Measure Bio-12 (Proposed to supersede APM BO-8 “Avoidance of and
minimization of potential impacts to song birds, raptors and other migratory bird
species”): Pre-construction bird nesting surveys for pull sites or locations of pole
replacement or clearing and grading activities would be conducted before work performed
between February 1 and August 15. See mitigation measure Bio-9 for pre-construction
survey requirements near the Santa Ynez River. Pre-construction surveys would be
conducted within the ROW and from the ROW of areas visible from the ROW. To the
extent possible, working in the vicinity of active nests would be avoided; however, if
avoidance is not practicable, a buffer zone, as determined by a qualified biologist, would
be maintained around the active nest to prevent nest abandonment. In the event that work
would take place within 50 feet (300 feet for raptors) of an active nest, a biological monitor
would monitor the activity of the nesting birds during work to determine if construction
activities are resulting in significant disturbance to the birds. If the qualified biologist
determines that work is disrupting nesting, then work in that area would be halted until
nesting is completed and the young have fledged. Monitoring guidelines would be
provided in an Avian Protection Plan to be submitted to the USFWS and CDFG for review
and approval prior to construction. Documentation of Plan approval would be submitted
to the CPUC for recordkeeping.
Installation of the replacement power lines would conform to PG&E’s most current version
of Bird and Wildlife Protection Standards, and would include the use of bird guards.
Verify the completion
of survey through
documentation.
Verify CDFG and
USFWS approval of
Avian Protection
Plan through
documentation.
Prior to construction
Verify appropriate
buffers and/or on-site
monitors are
established. Verify
power line
conformance with
Bird and Wildlife
Protection Standards
through
documentation.
During construction
surrounding an
active nest.
APM CR-1 APM Cultural Resources (CR)-1: Archaeological site avoidance. To ensure that Æ-1857-
3H is not inadvertently damaged during implementation of the Project, the limits of the
work areas listed in Potential Impact CR-1 will be marked with readily visible flagging
tape and the construction crews will be instructed that there will be no vehicle access,
travel, equipment staging and storage, or other construction-related work outside of the
flagged work areas when working at Pole 13.
Verify that the
cultural site is clearly
marked and avoided
through on-site
monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-15
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
APM CR-2 APM CR-2: Pre-construction Worker Education Program. PG&E will design and
implement a Worker Education Program that will be provided to all Project personnel who
may encounter and/or alter historical resources or unique archaeological properties,
including construction supervisors and field personnel. No construction worker will be
involved in field operations without having participated in the Worker Education
Program. The Worker Education Program shall include, at a minimum:
A review of archaeology, history, prehistory and Native American cultures
associated with historical resources in the Project vicinity.
A review of applicable local, state and federal ordinances, laws and regulations
pertaining to historic preservation.
A discussion of site avoidance requirements and procedures to be followed in the
event that unanticipated cultural resources are discovered during
implementation of the Project.
A discussion of disciplinary and other actions that could be taken against persons
violating historic preservation laws and PG&E policies.
A statement by the construction company or applicable employer agreeing to
abide by the Worker Education Program, PG&E policies and other applicable
laws and regulations.
The Worker Education Program may be conducted in concert with other environmental or
safety awareness and education programs for the Project, provided that the program
elements pertaining to cultural resources are provided by a qualified instructor meeting
applicable professional qualifications standards.
Verify required
content in the WEP.
Prior to construction
APM CR-3 APM CR-3: Unanticipated discoveries management. In the unlikely event that previously
unidentified cultural resources are uncovered during implementation of the Project, all
work within 165 feet (50 meters) of the discovery will be halted and redirected to another
location. PG&E’s cultural resources specialist or his/her designated representative will
Verify the
implementation of
proper procedures
through
During a discovery
of a previously
unidentified cultural
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-16 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
inspect the discovery and determine whether further investigation is required. If the
discovery can be avoided and no further impacts will occur, the resource will be
documented on State of California Department of Parks and Recreation cultural resource
records and no further effort will be required. If the resource cannot be avoided and may
be subject to further impact, PG&E will evaluate the significance and CRHR eligibility of
the resources, and implement data recovery excavation or other appropriate treatment
measures if warranted.
documentation and
on-site monitoring
resource
MM Cultural-1 Mitigation Measure Cultural-1: Environmental training would be provided to workers
regarding the protection of paleontological resources and procedures to be implemented in
the event fossil remains are encountered by ground-disturbing activities. This training may
be combined with other environmental training for the project, provided that the program
elements pertaining to cultural resources are provided by a qualified instructor meeting
applicable professional qualification standards.
In the unlikely event that previously unidentified paleontological resources are uncovered
during implementation of the project, all ground disturbing work would be temporarily
halted or diverted away from the discovery to another location. PG&E’s paleontological
resources specialist or his/her designated representative would inspect the discovery and
determine whether further investigation is required. If the discovery is significant, but can
be avoided and no further impacts would occur, the resource would be documented in the
appropriate paleontological resource records and no further effort would be required. If
the resource is significant, but cannot be avoided and may be subject to further impact,
PG&E would evaluate the significance of the resources, and implement data recovery
excavation or other appropriate treatment measures as recommended by a qualified
paleontologist.
Verify required
content in the
environmental
training
documentation.
Prior to construction
Verify training of
paleontological
resources and
procedures
documentation.
Verify the
implementation of
procedures through
documentation and
on-site monitoring.
During construction
and during a
discovery of a
previously
unidentified
paleontological
resource
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-17
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
APM GM-2 APM GM-2: Soft or loose soils during construction minimization. Where soft or loose
soils are encountered during construction, appropriate measures will be implemented to
avoid, accommodate, replace, or improve soft or loose soils encountered during
construction. Such measures may include:
Locating construction facilities and operations away from areas of soft
and loose soil.
Over-excavating soft or loose soils and replacing them with
engineered backfill materials.
Increasing the density and strength of soft or loose soils through
mechanical vibration and/or compaction.
Treating soft or loose soils in place with binding or cementing agents.
Construction activities in areas where soft or loose soils are
encountered will be scheduled for the dry season to allow safe and
reliable equipment access.
Verify appropriate
measures have taken
place through on-site
monitoring
During construction
at location with soft
or loose soils
APM
HM-2/WQ-2
APM HM-2/WQ-2: Environmental Training and Monitoring Program (ETMP)
development and implementation. An environmental training program will be
established to communicate to all field personnel any environmental concerns and
appropriate work practices, including spill prevention and response measures and Best
Management Practices (BMPs). The training program will emphasize site-specific physical
conditions to improve hazard prevention (e.g., identification of flow paths to nearest
waterbodies) and will include a review of all site-specific plans, including but not limited
to the Project’s SWPPP, Erosion Control and Sediment Transport Plan, Health and Safety
Plan, and Hazardous Substances Control and Emergency Response Plan.
A monitoring program will also be implemented to ensure that the plans are followed
throughout the construction period. BMPs, as identified in the Project SWPPP and Erosion
Control and Sediment Transport Plan, will also be implemented during the Project to
Verify required
content in the WEP.
Prior to construction
Verify training and
implementation of
ETMP through
documentation and
on-site monitoring.
During construction
Verify
implementation of
ETMP through
documentation and
During operation
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-18 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
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Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
on-site monitoring.
MM Haz-1 Mitigation Measure Haz-1 (Proposed to supersede APM HM-1): PG&E would submit a
Hazardous Substance Control and Emergency Response Plan to the CPUC for
recordkeeping at least 30 days prior to project construction. The plan would identify
methods and techniques to minimize the exposure of the public to potentially hazardous
materials during all phases of project construction through operation. The plan would
require implementing appropriate control methods and approved containment and spill-
control practices (i.e., spill control plan) for construction and materials stored on-site.
All hazardous materials and hazardous wastes would be handled, stored, and disposed of,
in accordance with all applicable regulations, by personnel qualified to handle hazardous
materials. With the exception of the poles, all hazardous materials would be collected in
project-specific containers at the site, and transported to a PG&E service center designated
as a PG&E consolidation site. Poles would be scheduled for transportation to the
appropriate licensed Class 1 or a composite-lined portion of a solid waste landfill. The plan
Verify required
content in the
Hazardous Substance
Control and
Emergency Response
Plan.
30 days prior to
construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-19
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
would include, but not be limited to, the following:
Proper disposal of potentially contaminated soils
Vehicles and equipment parking near sensitive resource areas during construction
Emergency response and reporting procedures to address hazardous material
spills
Stopping work and contacting the County Fire Department, Hazardous Materials
Unit (HMU) immediately if visual contamination or chemical odors are detected.
The resumption of work would require the approval of the HMU. Work would be
resumed at this location after any necessary consultation and approval by the
HMU.1
Notifying the appropriate Certified Unified Program Agency (CUPA) inspector of
the storage and disposal locations for wooden poles removed, prior to initiating
construction
Verify
implementation of
Hazardous Substance
Control and
Emergency Response
Plan through
documentation and
on-site monitoring.
During construction
with exposure to
hazardous materials
Hazardous
Substance
Control and
Emergency
Response Plan
ON-SITE REFUELING
If on-site refueling is needed, no vehicles or equipment will be refueled within 100 feet of a
stream with a defined stream channel or bank, a wetland, or a pond unless a bermed and
lined refueling area is constructed, secondary containment is otherwise in place, or the
refueling area is down gradient or hydrologically separated (e.g. such as a site across a
road and down gradient of the wetland).
Verify refueling is
occurring in
appropriate locations
through on-site
monitoring
During refueling
events
HAZARDOUS DISPOSAL
With the exception of the poles, all hazardous materials would be collected in project-
specific containers at the site, and transported to a PG&E service center designated as a
Verify disposal is
occurring
appropriately
During construction
11 The CPUC and PG&E agreed on June 22, 2010 to change the last sentence of the second to last bullet of Mitigation Measure Haz-1 in order to clarify the process to resume work.
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-20 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
PG&E consolidation site. Poles removed from the Project would be scheduled for
transportation to the appropriate licensed Class 1 or a composite-lined portion of a solid
waste landfill.
If potentially contaminated soils are discovered (e.g. based on odor, color, sheen), then
work at the site would be halted, the soil would be collected and contained while awaiting
test results (i.e. in a drum). The soil will be sampled, analyzed, and characterized to
determine proper disposal.
through on-site
monitoring.
HAZARDOUS SUBSTANCE RELEASE RESPONSE PLAN
The Hazardous Substance Release Response Plan is to be followed as a control measure in
the event of a hazardous substance release. Steps included,
Initial response
Containment techniques
Emergency coordinator duties
Emergency response plan
Clean up of insulating oil
Sampling requirements
Transportation and handling of release clean up debris hazardous waste
Notifications
Document retention
Verify Hazardous
Substance Release
Response Plan
through
documentation.
During hazardous
spills
MM Haz-2 Mitigation Measure Haz-2 (Proposed to supplement APM HM-2/WQ-2): PG&E would
prepare a site-specific Health and Safety Plan (HSP) to ensure that potential safety hazards
would be kept at a minimum. The HSP would include elements that establish worker
training and emergency response procedures relevant to project activities. The plan would
Verify required
content in the Health
and Safety Plan
30 days prior to
construction
Verify training and During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-21
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
be submitted to the CPUC at least 30 days prior to construction for CPUC recordkeeping. implementation of
HSP through
documentation and
on-site monitoring.
Verify
implementation of
HSP through
documentation and
on-site monitoring.
During operation
Health and
Safety Plan
All personnel working on this project or in the area of this project will read and be familiar
with this HASP before doing any work. All project personnel will sign the certification
page acknowledging that they have read and understand this HASP.
Verify training logs
to ensure that all
project personnel
have signed the
certification page
through
documentation.
During construction
WORKER BOUNDARIES – ENERGIZED LINES
When work will occur near energized electrical lines, clearly defined work boundaries and
limits will be established (e.g. applicable regulations, including NFPA 70E). A 25-foot set-
back distance from live electrical lines is the communicated safe working distance for
mobile equipment.
Physical barriers will be constructed, if necessary, to limit equipment proximity and warn
operators of this hazard. Qualified, high voltage electrical workers may work closer than
25 ft to energized conductors.
Verify distance of
workers from
energized electrical
lines through on-site
monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-22 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
FLAME RETARDANT CLOTHING
Every person will ensure that they wear Flame Retardant (FR) clothing that has an arc
rating greater than or equal to the available hear energy whenever they are within the Arc
Flash Boundary. In addition, everyone will ensure that they wear clothing that cannot melt
or ignite and continue to burn in the presence of electric arcs to which personnel could be
exposed, whenever they are working on or around PG&E electrical facilities. All garments
will have tags visible from the outside that clearly identified the garment as Flame
Resistant and clearly indicates the arc rating (HRC category) of the garment. All garments
will have a minimum rating of HRC 2. PG&E personnel will refer to the PG&E Flame-
Resistant (FR) Clothing Procedures (Utility Work Procedure WP2509) to determine the
appropriate Flame Retardant clothing for this Project.
Verify flame
resistance of worker’s
clothing within 12 ft
of the 115kV line
through on-site
monitoring.
During construction
SAFETY VESTS
When deciding which vest (Class III or Class II) to wear, employees will comply with the
following regulations:
Class III vests are required in traffic areas where vehicle speeds exceed 50 mph; high
volume traffic and unmonitored equipment movement; users and vehicle operators with
multi-task loads that divert attention and increase risk; complex backgrounds; work
activities taking place in or near unimpeded vehicle traffic; work activities taking place
under icy or snowy conditions; and work activities taking place in low light or at
nighttime.
A traffic area is defined as any roadway, highway, freeway, street or parking lot area, as
well as construction sites and PG&E yards where employees on foot are exposed to
moving construction vehicles or equipment.
Additionally, the Class III vests are Flame Retardant, can be worn in Arc Flash Hazard
boundaries. In addition to the new safety vests, the long-sleeve orange FR shirt with
reflective material also meets the Class III standard and the ANSI visibility standard.
Verify proper vest are
being worn by
construction
personnel through
on-site monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-23
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
Employees wearing these shirts are not required to wear a safety vest over them.
Class II vests are required in all other situations (day or night at speeds under 50 mph).
Class II vests are Flame Retardant, can be worn in Arc Flash Hazard boundaries.
TAIL GATE MEETINGS
Tailgate safety briefings will be conducted, as needed, at the beginning of the work day, or
as tasks/hazards change. Each tailgate safety briefing will be documented on the form
included in the Site Activities Tailgate Health and Safety Briefing Form. This briefing form
documents the tailgate briefing conducted in accordance with the HASP. Personnel who
perform work operations on site are required to attend each briefing and to acknowledge
receipt of each briefing, at least daily.
Verify tailgate
meetings through
documentation.
During construction
SAFETY EQUIPMENT
All employees working on this project must be shown the location and proper use of all
emergency equipment prior to beginning work on the project.
Verify workers
knowledge of safety
equipment location
and use through on-
site monitoring.
During construction
SUBCONTRACTORS
In the event that the subcontractor’s procedures/requirements conflict with requirements
specified in this HASP, the more stringent guidance will be adopted after discussion and
agreement between the subcontractor and project health and safety personnel. Hazards not
listed in this HASP, but known to the subcontractor or known to be associated with the
subcontractor's services, must be identified and addressed to the project or task manager
and construction crew foreman prior to beginning work operations.
The “Subcontractor Acknowledgement Memo” must be signed and dated by the
subcontractor’s management and placed in the project file before they can begin work on
the project. Once the signed memo is received by the project manager, this HASP can be
provided to the subcontractor to use as their own. Subcontractors working at the project
Verify subcontractors
Memo is signed and
included in the
project record
through
documentation.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-24 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
site will need to have this plan with them, and will also need to sign the Subcontractor
HASP receipt signature page.
MM Haz-3 Mitigation Measure Haz-3: If it is necessary to store any chemicals on-site, they would be
managed in accordance with all applicable regulations. Material Safety Data Sheets would
be maintained and kept available on-site, as applicable.
Verify that stored
chemicals have the
MSDS on-site and are
being stored in
accordance with
applicable
regulations through
documentation and
on-site monitoring.
During construction
MM Haz-4 Mitigation Measure Haz-4: In the event that soils suspected of being contaminated (based
on evidence from visual, olfactory, or other means) are removed during excavation
activities along the power line corridor, the excavated soil would be tested and, if
contaminated above hazardous levels, would be contained and disposed of at a licensed
waste facility. The presence of known or suspected contaminated soil would require
testing and investigation procedures to be supervised by a qualified person, as
appropriate, to meet state and federal regulations.
Verify appropriate
testing of potentially
contaminated soils
through
documentation and
on-site monitoring.
During construction
MM Haz-5 Mitigation Measure Haz-5 (Proposed to supersede APM HM-3): PG&E would prepare
and submit a Fire Prevention and Response Plan to the CPUC and to local fire protection
authorities for notification at least 30 days prior to construction. The plan would include
fire protection and prevention methods for all components of the project. The plan would
include procedures to reduce the potential for igniting combustible materials by
preventing electrical hazards, use of flammable materials, and smoking onsite during
construction and maintenance procedures. Project personnel would be directed to park
away from dry vegetation; to equip vehicles with fire extinguishers; not to smoke; and to
Verify required
content in the Fire
Prevention and
Response Plan.
30 days prior to
construction
Verify
implementation of
Fire Prevention and
Response Plan
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-25
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
carry water, shovels, and fire extinguishers in times of high fire hazard. The plan would
also include contacting the Santa Barbara County Fire Department when work is
scheduled on Red Flag Days as designated by the National Weather Service.
through
documentation and
on-site monitoring.
Verify coordination
with SBCFD on Red
Flag Days through
documentation.
During operation
Fire prevention
and Response
Plan
FIRE PREVENTION
All employees shall observe all laws, rules, and regulations of fire agencies having
jurisdiction over areas in which they are working (including work areas outside the project
site).
No employee shall perform any operation or action which could result in vegetation or
forest fires.
No employee shall smoke at or in the vicinity of the project site, except in designated areas
that are cleared of vegetation. Employees shall make every attempt to park away from dry
vegetation. Management of any flammable materials at the project site will be in a manner
to minimize fire risk potential.
Verify fire laws are
being followed
through on-site
monitoring.
During construction
FIRE RATINGS
The person in charge shall also be aware of the possibility of increased fire danger during
the time work is in progress. The person will contact the Santa Barbara County Fire
Department when work is scheduled on Red Flag Days as designated by the National
Weather Service.
Additionally, through arrangements with the California Department of Forestry and Fire
Protection (Cal Fire) and the United States Forest Service, PG&E is notified daily during
the California “Fire Season” when next-day fire adjective ratings of Very High or Extreme
Verify Fire Ratings
are followed as
appropriate through
on-site monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-26 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
are calculated for any adjective rating zone within PG&E’s service territory. The rating
received by PG&E is the prediction of the most severe rating expected for that area the
following day and is used as the rating for that day. This information posted on the PG&E
Intranet at: http://www/fireindex/
The rating is posted by 2100 hours (9:00 p.m.) each day and becomes effective at 0800
hours (8:00 a.m.) the following day.
Effective hours of fire adjective ratings, unless canceled or extended by local authorities,
are as follows:
Very High and Extreme: 0800 until 2 hours after local sunset time, daily.
All other ratings (Low, Medium, and High) do not have specific times noted.
REQUIRED FIRE EQUIPMENT
All personnel working in hazardous fire areas must be equipped with firefighting
equipment such as, but not limited to, shovels, axes, back pumps, fire extinguishers, etc.
Such equipment shall be maintained in good working condition at all times.
Company construction vehicles shall be furnished with the necessary fire prevention
equipment.
Verify personnel
working in
hazardous fire areas
must be equipped
with appropriate
firefighting
equipment through
on-site monitoring.
During construction
APM
WQ-2/HM-2
APM WQ-2/HM-2: Environmental Training and Monitoring Program (ETMP)
development and implementation. Worker environmental awareness will communicate
Verify required
content in the ETMP.
Prior to construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-27
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
environmental issues and appropriate work practices specific to this Project. This
awareness will include spill prevention and response measures and proper BMP
implementation. The SWPPP training will emphasize site-specific physical conditions to
improve hazard prevention (e.g., identification of flow paths to nearest waterbodies) and
will include a review of all site-specific water quality requirements, including applicable
portions of , the Erosion Control and Sediment Transport Plan, Health and Safety Plan,
and PG&E’s Hazardous Substances Control and Emergency Response program.
A monitoring program will also be implemented to ensure that the plans are followed
throughout the construction period. BMPs, as identified in the Project SWPPP and Erosion
Control and Sediment Transport Plan, will also be implemented during the Project to
minimize the risk of an accidental release and to provide the necessary information for
emergency response.
Verify training and
implementation of
ETMP through
documentation and
on-site monitoring.
During construction
MM Hydo-1 Mitigation Measure Hydro-1 (Proposed to supersede APM WQ-1): Following project
approval, PG&E would prepare and implement a SWPPP to minimize construction
impacts on surface and groundwater quality. Implementation of the SWPPP would help
stabilize graded areas and waterways and reduce erosion and sedimentation. The plan
would designate BMPs that would be adhered to during construction activities. Erosion
and sediment control measures, such as straw wattles, water bars, covers, silt fences, and
sensitive area access restrictions (e.g., flagging) would be installed before the onset of
winter rains or any anticipated storm events. Mulching, seeding, or other suitable
stabilization measures would be used to protect exposed areas during construction
activities, as necessary. During construction, measures would be in place to ensure that
contaminants are not discharged from the construction sites.
Verify required
content in the
SWPPP.
Prior to construction
Verify
implementation of
SWPPP through
documentation and
on-site monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-28 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
MM Hydo-2 Mitigation Measure Hydro-2 (Proposed to supersede APM WQ-3/GM-2): PG&E would
prepare an Erosion Control and Sediment Transport Plan (ECSTP) as an element of the
SWPPP describing BMPs, to be used during construction. The plan would address
construction in or near sensitive areas described in Section 3.5 Biological Resources. BMPs,
where applicable would be designed based on specific criteria from recognized BMP
design guidance manuals. Erosion-minimizing efforts may include measures such as:
Avoiding excessive disturbance of steep slopes
Defining ingress and egress within the project area
Implementing a dust control program during construction
Restricting access to sensitive areas
Using vehicle mats in wet areas
Revegetating disturbed areas where applicable following construction
Proper containment of stockpiled soils (including construction of
berms in areas near water bodies, wetlands, or drainage channels)
Erosion control measures identified in the ECSTP would be installed in an area before
clearing begins during the wet season in that area and before the onset of winter rains or
any anticipated storm events. Temporary measures such as silt fences or wattles, intended
to minimize sediment transport from temporarily disturbed areas, would remain in place
until disturbed areas have stabilized.
The ECSTP would be submitted to the CPUC for review at least 30 days prior to the
commencement of construction. The plan would be revised and updated as needed, and
re-submitted to the CPUC if construction activities evolve to the point that the existing
approved ECSTP does not adequately address the project.
Verify required
content in the ECSTP.
30 days prior to
construction
Verify
implementation of
ECSTP through
documentation and
on-site monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-29
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
APM Land Use
(LU)-1
Agriculture impacts avoidance. To avoid potential impacts to agriculture, PG&E will work
with farmers and ranchers to conduct its work between their harvest and planting periods
where and whenever possible. In areas containing permanent crops (i.e., grape vines, tree
orchard, etc.) that must be removed and replaced to gain access to poles sites for
construction purposes, PG&E will provide compensation to landowners for crop loss and
other reasonable and associated costs as soon as practicable after completion of
construction. Access across active crop areas will be negotiated with the owners in advance
of any construction activities.
Verify consultation
with local farmers
and ranchers through
documentation.
Verify that
negotiation of crop
compensation is
made through
documentation.
Prior to construction
Verify compensation
for lost crops through
documentation
Post-construction
APM NO-1 APM Noise (NO)-1: Noise minimization with portable barriers. Compressors and other
small stationary equipment will be shielded with portable barriers in proximity to
residential areas.
Verify use of noise
barriers through on-
site monitoring and
documentation
During construction
APM NO-2 APM NO-2: Noise minimization with “quiet” equipment. “Quiet” equipment (i.e.,
equipment that incorporates noise-control elements into the design—compressors have
“quiet” models) will be used during construction whenever possible.
Verify use of “quiet”
equipment through
on-site monitoring
and documentation
During construction
APM NO-3 APM NO-3: Noise minimization through direction of exhaust. Equipment exhaust stacks
and vents will be directed away from buildings
Verify direction of
stacks and vents
through on-site
monitoring
During construction
APM NO-4 APM NO-4: Noise minimization through truck traffic routing. Truck traffic will be Verify truck routes
through
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-30 Mitigation Monitoring, Compliance, and Reporting Program
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
routed away from noise-sensitive areas where feasible. documentation and
on-site monitoring
APM NO-5 APM NO-5: Noise disruption minimization through residential notification. PG&E will
coordinate with the City of Lompoc and the County of Santa Barbara to notify residents
that are located near the power lines of the timeframe for the construction activities.
Verify residents have
been notified through
documentation.
Prior to construction
MM Traffic-1 Mitigation Measure Traffic-1 (Proposed to supersede APM TT-1): PG&E would develop
a project-specific TMP, which would be submitted to the CPUC for review at least 30 days
prior to construction. The TMP would conform to the California Joint Utility Traffic
Control Committee’s Work Area Protection and Traffic Control Manual. The TMP would
include the following:
Standard safety practices, including installation of appropriate barriers
between work zones and transportation facilities, placement of
appropriate signage, and use of traffic control devices.
Flaggers and/or signage would be used to guide vehicles through or
around construction zones using proper construction techniques.
Provision that all equipment and materials would be stored in
designated staging areas on or adjacent to the work sites in a manner
that minimizes traffic obstructions and maximizes sign visibility.
Acceptable vehicle speeds on project roadways. Vehicle speeds would
be limited to safe levels as appropriate for all roads, including access
roads and overland routes without existing, posted speed limits.
Verify required
content in the TMP.
30 days prior to
construction
Verify the TMP is
properly
implemented
through
documentation and
on-site monitoring
During construction
Traffic
Management
Plan
TRAFFIC CONTROL
From the edge of the work area (PG&E’s ROW), appropriate traffic signage will be placed
at 1,000-foot intervals along SR 246, up to 3,100 feet to each side of the ROW. Appropriate
traffic signage will also be placed at 350-foot intervals along any crossroad up to 700 feet to
Verify traffic control
through on-site
monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
Cabrillo-Santa Ynez 115 kV Reconductoring Project F-31
June 2010
Mitigation Monitoring Program Table (Continued)
APM/
Mitigation
Measure
APM/Mitigation Measure Implementation/
Monitoring Method
Implementation
Schedule
each side of the ROW crossing. Flaggers will be posted to each side of the ROW
TRAFFIC SPEED
PG&E staff and contractors will follow posted vehicle speeds on project roadways. Vehicle
speeds will be limited to safe levels as appropriate for all roads, including access roads and
overland routes without existing, posted speed limits. Vehicle speed on unpaved roads is
limited to 15 miles per hour, except where safety considerations supersede this
requirement, e.g. when heavy loads approach a steep hill.
Verify project traffic
speed through on-site
monitoring.
During construction
APPENDIX F: MITIGATION MONITORING PROGRAM TABLE
F-32 Mitigation Monitoring, Compliance, and Reporting Program
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